What is MACRA and where does MIPS fit in?
MACRA, or the Medicare Access and CHIP Reauthorization Act of 2015, created the Quality Payment Program. Most providers will follow the MIPS track of the Quality Payment Program. The other option is to participate in the Alternate Payment Model, or APM. Please consult Medicare to make the correct choice between MIPS and APM for your practice. See below for assistance with MIPS.
By providing high quality, efficient care supported by technology, providers participating in MIPS may earn a positive payment adjustment to their Medicare reimbursement. MIPS centralizes the various EHR reporting initiatives required by Medicare. The combination of Meaningful Use, PQRS, and Value-Based Modifiers with new Improvement Activities creates the 4 MIPS categories to which providers must attest:
- Quality (Replaces PQRS)
- Improvement Activities (New Category)
- Advancing Care Information (Replaces Meaningful Use Reporting*)
- Cost (Replaces the Value- Based Modifier)
Providers can participate as individuals or as part of a group. To determine your participation options please consult CMS.
Image via qpp.cms.gov/mips/overview
There are 3 possible outcomes available to providers for 2017 attestations:
- Positive Adjustment - If you submit a full year of 2017 data to Medicare, you may earn a positive payment adjustment OR If you submit 90 days of 2017 data to Medicare, you may earn a neutral or positive payment adjustment and may even earn the max adjustment.
- No Adjustment - If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point in 2017), you can avoid a negative payment adjustment.
- Negative Adjustment - If you don’t send in any 2017 data, then you receive a negative 4% payment adjustment.
The Challenge with Traditional Research Recruitment
Recent study findings published by the Tufts Center for the Study of Drug Development revealed that 91% of physicians feel ‘somewhat’ or ‘very’ comfortable discussing the opportunity to participate in a clinical trial with patients, but these same providers only refer less than 0.2% of their patients into trials. Along those same lines, more than 80% of patients say they are willing to participate in clinical research studies, but only around 10% actually do.
These challenges stem from the fact that typically, patients must be receiving care at an investigative research site to be considered for trial enrollment. In reality, only a fraction of care providers – perhaps only one out of every eight – are registered as a 1572 primary investigator. The same holds true for the number of active research sites – a small number when compared with the total number of physician practices. Yet each year there are about one-billion office visits annually in the US, with nearly 100% of those being documented electronically via EMRs.
So couple an artificially limited pool of participants with increasing protocol complexity stemming from the burgeoning science of personalized medicine and it is no wonder that the vast majority of studies struggle to perform against enrollment objectives.
How can Aprima help?
Aprima is ready and equipped to help you succeed with the Merit-Based Incentive Program, or MIPS. Aprima is pleased to offer a MIPS Assistance Program for our customers. This is an optional service for those who feel uncomfortable navigating the process alone, or for those who want an extra level of oversight as they move into a more complicated and sometimes challenging stage of quality reporting.
This program is designed to assist you in understanding all of the requirements, choosing the measures that will yield the best data, and configuring your database to accurately and efficiently capture all of the necessary data. We will also assist you in submitting your data to CMS, when the time comes. It is important to note that practices must be diligent in the capture of clinical information. Also note, it is the sole responsibility of the practice to manage the Improvement Activity component of MIPS. This function can’t be outsourced.
Shifting the Paradigm
There are currently about 100,000 trials underway in the US, each in need of a very specific patient population. And because each protocol can have anywhere between 10-50 eligibility criterion, site staff often lack the time to complete thorough chart reviews in response to initial feasibility questionnaires. Instead a best guess of how many patients match criteria is provided, setting a potentially unrealistic level of expectations.
Meanwhile, other organizations, both internal and external to a sponsor, rely on a cadre of tools to identify or recruit patients. These include traditional print and radio/TV advertising, referral networks, social media and other forms of outreach that are leveraged partially from pharmacy sales data and/or partially the result of patient self-identification. And while these later approaches may drive some degree of success, they typically fail to reach the consistently underserved research populations of both the elderly and non-Caucasian races.
In order to get more targeted traction with the millions of patients falling outside of the traditional site network and recruitment channels, sponsors are finally stepping outside of the ‘conventional’ approach of “site-based patient identification” and embracing EMR data and modern technology – analytics, natural language processing, risk stratification and more. The outcome? Patient-based site identification, an approach that is truly patient-centric and involves the caregivers that can help support the patient’s decision-making process around participation and affect adherence over the course of the trial.
Patient iP invites interested Aprima customers to join our Connected Site Network so that practice patients can take advantage of appropriate research opportunities, with minimal overhead and burden to the practice itself.
- 1-on-1 initial consultation session with your office to determine the measures that you wish to report on
- System configuration
- MIPS Workflow consultation
- Recurring 1-on-1 meetings to review your current status
- Assistance submitting your data to CMS
*Certified Software is still required.
APRIMA DOES NOT GUARANTEE A PROVIDER OR PRACTICE WILL EARN OR AVOID ANY PENALTIES OR PAYMENT ADJUSTMENTS ASSOCIATED WITH DATA THAT IS REPORTED OR SUBMITTED. APRIMA WILL NOT INDEMNIFY ANY PROVIDER OR PRACTICE IN THE EVENT OF AUDIT FAILURE OR OTHER GOVERNMENTAL ACTIONS ASSOCIATED WITH ATTESTATION.