The AAOS Quality Payment Program (QPP) Information Center offers tools and resources to help you and your practice prepare for and navigate through either of the two QPP tracks - The Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs). For the most recent advocacy news, comment/congressional letters, and current AAOS position statements, see the "Advocacy" tab below. Have additional questions about the QPP? Contact firstname.lastname@example.org. Questions can also be submitted directly to CMS via email at QPP@cms.hhs.gov or (866) 288-8292.
The QPP includes two tracks: the Merit-based Incentive Payment System (MIPS) track and the Advanced Alternative Payment Models (APMs) track. You can choose how you want to participate based on your practice size, specialty, location, or patient population.
You're a part of the Quality Payment Program in 2019 if you are in an Advanced APM or if you have more than $90,000 in Part B allowed charges for covered professional services, provide care to more than 200 beneficiaries, or provide more than 200 covered professional services under the PFS (new criterion). You must both meet the minimum billing and the number of patients to be in the program. If you are below any of the low-volume threshold criteria, you are not in the program.
- Merit-based Incentive Payment System (MIPS) combines existing Medicare reporting requirements (i.e. Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-based Payment Modified (VPM)) into a single program that ties fee-for-serve payment to performance. Physicians will receive payment adjustments based on Quality, Promoting Interoperability, Clinical Improvement Activities, and Cost (resource use).
- Advanced Alternative Payment Models (APMs) is a payment approach that lets practices earn more for taking on some risk related to patients' outcomes. You may earn 5% Medicare incentive payment during 2019 through 2024 and be exempt from MIPS reporting requirements and payment adjustments if you have sufficient participation in an Advanced APMs.
2019 Program Year
MIPS will be the pathway for a majority of Orthopaedic Surgeons to participate in QPP. MIPS combines CMS's three existing reporting programs - Physician Quality Reporting System (PQRS), Value-based Modifier, and EHR Meaningful Use, under a single entity.
2019 MIPS Metrics
To calculate your MIPS score, CMS will evaluate your performance in four categories. Scores in each area will be weighted. CMS will adjust the weights for each category each program year.
- Quality - 45%
- Must submit data for at least 6 measures (or a complete specialty measure set) while one of these measures should be an outcome measure (if you have no applicable outcome measure, may submit another high priority measure instead)
- For groups of 16 or more clinicians who meet the case minimum of 200, the administrative claims-based all-cause readmission measure will be automatically scored as a seventh measure
- Data completeness requirements for Year 3
- Claims: 60% of Medicare Part B patients for the performance period.
- QCDR/Registry/EHR: 60% of clinician's or group's patients across all payers for the performance period.
- In Year 3, individual eligible clinicians can submit measures via multiple collection types (MIPS CQM, eCQM, QCDR measures, and for small practices, Medicare Part B claims measures).
- The small practice bonus will now be added to the Quality performance category, rather than in the MIPS final score calculation. 6 bonus points are added to the numerator of the Quality performance category for MIPS eligible clinicians in small practices who submit data on at least 1 quality measure.
- Promoting Interoperability (replaces ACI) - 25%
- Year 3 completely revamps the PI scoring methodology by eliminating the base, performance, and bonus scores; provides for performance-based scoring at the individual measure-level. Each measure will be scored based on the MIPS eligible clinician's performance for that measure based on the submission of a numerator or denominator, or a “yes or no” submission, where applicable.
- Finalized the Security Risk Analysis measure as a required measure without points.
- The scores for each of the individual measures will be added together to calculate the score of up to 100 possible points. If exclusions are claimed, the points for measures will be reallocated to other measures.
- Eligible clinicians must use 2015 Edition CEHRT in Year 3.
- Clinical Improvement Activities (CPIA) - 15%
- Category that focuses on care coordination, beneficiary engagement, and patient safety
- Modifications include the addition of one new criterion in this category, “Include a public health emergency as determined by the Secretary,” and the removal of, “Activities that may be considered for a Promoting Interoperability bonus.”
- List of orthopaedic-related improvement activities - In development
- Cost - 15%
- No reporting will be required for this category. CMS will calculate your score based on claims data in 2019 and report it to you via feedback report
- CMS added 8 new episode-based measures to the Cost performance category, including the Knee Arthroplasty measure which AAOS helped develop as part of the Musculoskeletal Clinical Subcommittee.
- Cost performance category percent score will not take into account improvement until the 2024 MIPS payment year.
For scoring Facility-Based Quality and Cost Performance Categories, the measure set for the fiscal year Hospital Value-Based Purchasing (VBP) program that begins during the applicable MIPS performance period will be used for facility-based clinicians (FY 2020 for 2019 performance period).
Scoring: A single MIPS composite performance score will factor in performance in the four weighted categories. Orthopaedic Surgeons can receive positive or negative payment adjustments based on their composite performance score. There will be "winners" and "losers".
Advanced APMs will be the less chosen pathway for Orthopaedic Surgeons in 2017. This option lets practices earn more for taking on some risk related to their patients' outcomes. If you decide to take part in an Advanced APM, you may earn a Medicare incentive payment for participating in an innovative payment model.
The 2019 Quality Payment Program rule changes amended the Advanced APM quality criteria to state that at least one of the quality measures upon which an Advanced APM bases payment must be:
- On the MIPS final list,
- Endorsed by a consensus-based entity, or
- Otherwise determined by CMS to be evidence-based, reliable, and valid. This provision applies beginning in 2020
CMS also increased the CEHRT use threshold for Advanced APMs so that an Advanced APM must require at least 75% of eligible clinicians in each APM Entity use CEHRT to document and communicate clinical care with patients and other health care professionals.