Plexus Industry and Market News: eAlerts

eAlerts are the latest industry information regarding regulatory changes, helpful compliance reminders, or any number of relevant topics in the fast-paced, ever-evolving specialty of anesthesia.

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February 13, 2019

The Department of Health and Human Services has issued two new proposed rules designed to enhance interoperability across the health system, facilitate health data sharing and increase patient access to their health information.  The long-awaited proposals were announced this week as the Health Information Management Systems Society (HIMSS) launched its 2019 meeting in Orlando.

The Interoperability and Patient Access Proposed Rule, released by the Centers for Medicare and Medicaid Services (CMS), outlines strategies for making patient data more transferable in open, secure, standardized formats.  Comments on the proposed rule as well as two requests for information (RFIs) on interoperability and health information technology in post-acute care settings are being accepted until early April.  (The exact date will be published soon in the Federal Register.)

“Electronic health information has been stuck in silos and inaccessible for healthcare consumers,” CMS Administrator Seema Verma said in a statement.  “We ask that members of the healthcare system join forces to provide patients with safe, secure access to, and control over, their healthcare data.”

Stating that “timely electronic access to health information makes it easier for people to make more informed decisions about their healthcare needs,” CMS proposes to require Medicare Advantage (MA) organizations, state Medicaid and CHIP programs and participants in other federally funded programs to adopt standardized application programming interfaces (APIs) to give patients access to their claims and other health information through third-party applications and developers.  The proposal would build on CMS’s Blue Button 2.0 API for Medicare fee-for-service beneficiaries, launched last year.

CMS is also proposing to: 

  • Require CMS program participants to facilitate electronic data exchange that would support care transitions as patients move between plan types. If finalized, the proposal would give an estimated 125 million Americans access to their health information across programs.
  • Require program participants to provide patients with access to provider directories through API technology.
  • Enable payers and providers in CMS programs to participate in trusted exchange networks that would support the secure and private flow of data nationwide.
  • Update the frequency of certain Medicare/Medicaid data on dually eligible beneficiaries from monthly to daily exchanges to improve benefit coordination for this population.
  • Motivate clinicians and hospitals to refrain from information blocking (unreasonably limiting availability of electronic health information) by publishing names of clinicians and hospitals that have submitted a “no” response to any of the three attestation statements regarding information blocking prevention in CMS’s Promoting Interoperability Program.
  • Publicly report the names and National Provider Identifiers (NPIs) of providers who have not added digital contact information to their entries in the National Plan and Provider Enumeration System (NPPES) by the second half of 2020. The NPPES was updated in 2018 to include one or more pieces of digital contact information to facilitate the secure sharing of health data.
  • Revise the Conditions of Participation to require hospitals, psychiatric hospitals and critical access hospitals to send electronic notifications when a patient is admitted, discharged or transferred.

The Office of the National Coordinator for Health Information Technology (ONC) has released the 21st Century Cures Act:  Interoperability, Information Blocking and the ONC Health IT Certification Program proposed rule.

The rule would implement provisions of the 21st Century Cures Act, including reasonable and necessary activities that do not constitute information blocking.  Aligned with the CMS Interoperability proposed rule, the ONC proposal “would support patients in accessing and sharing their electronic health information while giving them the tools to shop for and coordinate their own healthcare,” said Don Rucker, national coordinator for health IT, in a statement.  Health information networks and health information exchanges that violate the rule could receive a penalty of $1 million for each instance of information blocking.

Under the proposal, an instance in which a patient requests their electronic record and does not receive it, free of charge, could be considered information blocking, according to Elise Sweeney Anthony, director of the ONC Office of Policy, speaking at HIMSS 2019.

The proposed policy identifies seven exceptions in which providers and healthcare IT companies could withhold electronic health data.  They are:

  • To prevent physical harm to a patient or another person
  • To protect privacy, including several sub-exceptions listed by ONC
  • To promote cybersecurity
  • To recover costs incurred in sharing health data
  • To decline a request for data sharing that is “infeasible”
  • To license interoperability tools, provided the agreement is fair and reasonable
  • To conduct maintenance or improvements to health IT.

Both the CMS and ONC proposed rules “address both technical and healthcare industry factors that create barriers to the interoperability of health information and limit a patient’s ability to access essential health information,” according to an HHS statement.  “Aligning these requirements for payers, healthcare providers, and health IT developers will help to drive an interoperable health IT infrastructure across systems, ensuring providers and patients have access to health data when and where it is needed.”

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February 4, 2019

Summary: Despite some potential pitfalls, health information technology can be used to improve anesthesia quality in a multitude of ways. In a follow-up to last week’s eAlert, we provide additional examples from a presentation on the use of HIT in anesthesia at PRACTICE MANAGEMENT™ 2019.

In last week’s eAlert, we discussed some of the ways that health information technology (HIT) can be harnessed to improve quality in anesthesia. With proper implementation and vigilance in the face of the added distractions that can come with automation, HIT can help drive improvements in documentation, clinical decision-making, financial performance, clinician satisfaction and much more.

This eAlert reviews additional examples of HIT’s successful use in anesthesia quality improvement from the presentation by Mark A. Deshur, MD, MBA, of NorthShore University HealthSystem, at the ASA’s PRACTICE MANAGEMENT™ 2019 in Las Vegas.

Manage use of blood products.  Anesthesiologists at Johns Hopkins Medical Institutions analyzed AIMS blood utilization data for approximately 53,000 patients who underwent 1,600 different types of procedures at the health system to develop an updated maximum surgical blood order schedule (MSBOS) for each specialty.  They used an algorithm that divided surgical procedures into categories based on blood loss and the need for blood products.

Retroactively applying the new algorithm to the 53,000 cases, they found that 27,000 of the cases did not require any preoperative blood orders; however, of those cases, 32.7 percent had a type and screen and 9.5 percent had a crossmatch ordered.  Using the MSBOS to eliminate the unnecessary blood orders, they calculated a potential savings of $211,000 in hospital charges and $43,000 in actual costs.  Since then, Johns Hopkins Medical Institutions has implemented a system-wide blood management program that has yielded more than $2 million in savings.

Increase medication safety with smart labeling.  Dr. Deshur said that smart labeling systems have been shown to greatly reduce serious medication errors.  Barcode-assisted syringe labeling systems, for example, allow providers to scan the manufacturer’s barcode on a vial before drug preparation, print a Joint Commission-compliant syringe label that includes the barcode, drug concentration and other pertinent information, and scan the syringe label barcode immediately before administering the drug to the patient.  To support accuracy, some systems provide visual and audio read-back of the drug name and concentration when the label is scanned.

[A 2016 Anesthesiology study found that one in 20 perioperative medication administrations involved a medication error and/or an adverse drug event.  The study suggested that barcode-assisted syringe labeling systems have potential to eliminate labeling errors, and that point-of-care barcode-assisted documentation systems that allow providers to scan the syringe label immediately before administration and populate the AIMS may help reduce documentation errors as well.]

Streamline professional practice evaluations.  Dr. Deshur’s institution leveraged its anesthesia staff scheduling software to automate the professional practice evaluations mandated annually by the Joint Commission.  The scheduling system includes pop-up screens that list all of the clinicians who have worked with a given physician or nurse anesthetist during the year.  An evaluation form can be sent to each of the clinicians who have worked with a provider by simply clicking on their name.

Completed evaluations are indicated on the screen in green; red shows that the evaluation has not yet been submitted.  “We took an onerous process, automated it and made it simple,” said Dr. Deshur.  Before the project, “one of the biggest complaints was ‘this person’s evaluating me and I’ve never worked with them.’ Now we’re getting real feedback that matters.”  

Optimize staff scheduling.  The dashboard of NorthShore University HealthSystem’s anesthesia staff scheduling system uses an algorithm based on historical averages and numbers of people scheduled to work on given days to predict, and indicate by color, days of the month when staffing will be sufficient (green), tight but workable (yellow), and insufficient (pink) in the hospitals’ operating rooms.

“Staff see days they are not scheduled to work where we need help, or days they are scheduled to work where maybe we have a few extra people and they can take that day off,” Dr. Deshur explained. “It gives people an opportunity to switch days and put their name on a volunteer calendar or pick up an extra shift, take a vacation day, come in a little early or stay a little late.”  The staffing dashboard “increases our flexibility and helps us match our demand for services with our supply of staff.”

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January 28, 2019

Anesthesia providers typically think of anesthesia information management systems (AIMS) and electronic health records (EHR) when they think of health information technology (HIT) in anesthesia, but HIT’s potential uses in the specialty reach much farther.  HIT can be harnessed to ensure appropriate documentation, drive smarter clinical decisions, boost provider satisfaction, bolster financial performance, promote medication safety and more.

As long as anesthesia providers remain vigilant and don’t fall prey to the common but mistaken assumption that HIT systems are fail-safe, technology can fuel important efficiencies and improvements in anesthesia quality, Mark A. Deshur, MD, MBA, of NorthShore University HealthSystem, said in a presentation at the ASA’s PRACTICE MANAGEMENT™ 2019 in Las Vegas.

“Quality has to be more than a promise,” Dr. Deshur said, referring to Ford Motor Company’s past motto, ‘Quality is Job 1’. “It’s easy to make a promise. It’s much harder to actually deliver on that promise,” he said.

Still, if properly implemented, technology can be a powerful quality improvement tool, said Dr. Deshur, whose talk included several successful examples at his institution and others that we’ll highlight this week and in future eAlerts. 

Harvest AIMS data to identify problems.  After spotting an instance of failure to document placement of an arterial line in their practice, Dr. Deshur and his colleagues at NorthShore University HealthSystem used data gathered from their AIMS dashboard to identify how often practitioners had failed to document placement of A-lines and central lines during the previous 10 months, discovering that “this was not an isolated incident; this was a much bigger problem.”  They built functionality into the AIMS that looks for invasive A-line or C-line data and sends a reminder to the anesthesia provider if documentation is still missing 30 minutes after line placement.

When clinicians click the reminder, they’re taken to a place in the AIMS that allows them to easily document line placement.  During the previous 10 months, the department had identified 16 A-line documentation failures per month and a total of six C-line documentation failures during that time.  By using a dashboard to identify and track the problem, the department was able to implement a successful practice change that has yielded $15,000 in additional revenue annually.

Reduce excess fresh gas flow usage.  Anesthesiologists at the University of Washington, Seattle, used a clinical decision support tool to notify clinicians when fresh gas flows (FGF) exceeded 1 liter/minute.  If sevoflurane usage reached 2 minimum alveolar concentration-hours under low flow anesthesia (FGF<2 l/min), a second reminder was sent to increase FGF to 2 l/min to comply with Food and Drug Administration guidelines.

Mean FGF between incision and end of procedure were compared 1) at baseline; 2) when decision support to reduce FGF was applied; 3) when the decision rule was deliberately inactivated; and 4) when the decision rule was reactivated. The simple real-time reminder to lower fresh gas flow resulted in an annual cost savings of $100,000.  After implementing a similar FGF reminder at their institution, NorthShore HealthSystem is saving an estimated $25,000 per year, Dr. Deshur reports.

Lower labor epidural re-dose rates.  The access to discrete data made possible by some HIT systems can make it easier to retrieve and analyze that data to highlight different practice patterns and enable clinicians to improve their practices in ways that they never could before.  A review of data on labor epidural re-dose rates at NorthShore “opened our eyes to the fact that we could do better,” Dr. Deshur said.  Data showing re-dose rates ranging from 17 percent to 41 percent among the group’s 45 anesthesiologists allowed the department to identify that it had a problem and start diving into it to identify what it could do better.

After a literature review to identify best practices, the department adopted patient-controlled epidural analgesia for labor at both of its hospitals, changed infusions to be consistent at both facilities and encouraged providers to switch to combined spinal epidurals from straight epidurals.

A review of the data since implementing these changes revealed an average re-dose rate of 15 percent across the department, “a substantial improvement we never would have even thought to make if we didn’t see these types of trends,” said Dr. Deshur.

Dr. Deshur highlighted some of the inherent challenges and potential pitfalls of technology in his talk as well.  Among these is the very real risk of distraction that comes with HIT, which means that the need for “vigilance rings true now more than ever,” he said. Another is complexity.  “As our systems become more automated and complex, the assumption is that they’re foolproof, except that every system has limitations, and it’s not always clear what those limitations are and how the system will perform if those limitations are exceeded,” he said, citing reports that the Tesla Model S has driven into fire trucks stopped on highways because the electric car’s semiautonomous system could not detect the obstacles and the drivers had become complacent.  “What happens if you have increasingly automated systems that lead to decreased vigilance?”

Still, though technology is far from perfect, Dr. Deshur said that with an understanding of the nuances and challenges, “HIT can help ensure we document appropriately, offer clinical decision support tools that allow us to make smarter decisions, enhance our bottom line through improved charge capture and lower costs,” and improve the practice of anesthesia in countless other ways. 

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January 22, 2019

Summary: The budget neutrality required by MACRA and the high performance by anesthesia and pain management groups in the Quality Payment Program so far means that providers within the specialty are unlikely to earn significant bonuses by participating in MIPS in 2019. However, compelling reasons to continue reporting remain: 1) insurance carriers continue to require it; 2) hospitals and facilities continue to request it; and 3) practice trend data is a valuable asset for organizational reviews. We encourage providers to review the quality measures awaiting approval by CMS through the MiraMed QCDR in order to begin planning for 2019.

As with any federal healthcare program, the Merit-Based Incentive Payment System (MIPS) continues to change and evolve.  2019 doesn’t break from that trend. This eAlert will review the currently available information regarding changes to the MiraMed Qualified Clinical Data Registry (QCDR) for anesthesia and chronic pain management providers resulting from the 2019 program updates. We will provide further information when the Centers for Medicare and Medicaid Services (CMS) publishes final notifications regarding the QCDR measures. 

2019 MIPS Highlights

Many features of the MIPS program remain the same for 2019, providing a level of consistency for anesthesia and chronic pain management practitioners that we haven’t enjoyed so far under MACRA and MIPS.  There are a few noteworthy items to keep in mind with regard to 2019 MIPS compliance.  Specifically:

  • Payment adjustments for 2021 based on 2019 reporting will increase to +/- 7% (bonus/penalty).
  • The performance minimum threshold has increased from 15 points in 2018 to 30 points in 2019.
  • Performance period requirements are the same for 2019 as they were in 2018:
    • Quality: 12-month calendar year performance period
    • Cost: 12-month calendar year performance period
    • Promoting Interoperability: 90 days minimum performance period.
    • Improvement Activities: 90 days minimum performance period.

CMS estimates that 91.2 percent of all MIPS eligible clinicians will receive positive or neutral payment adjustments.  That level of participation will continue to depress the bonus that you could earn, so please keep that in mind when evaluating whether to participate in 2019.  It is not likely that any anesthesia provider or group will receive the full 7 percent bonus for MIPS participation.

Quality Reporting Changes: What Did We Lose?

The program has grown in size and scope, but along the way, several measures have been classified as “topped out,” and therefore, CMS no longer considers these measures useful in evaluating providers.  This elimination of topped out measures represents medicine’s continuing effort to find measures that meet the goals of proper evaluation of a provider’s and group’s quality without causing undue cost and workflow disruption to patient care.  As we all continue to seek measures that balance these two competing drivers, we are bound to lose measures along the way. 

The following measures are not eligible for reporting in 2019:

  • MIPS426 – Post-Anesthetic Transfer of Care Measure: Procedure Room to a Post-Anesthesia Care Unit (PACU)
  • MIPS427 – Post-Anesthetic Transfer of Care: Use of Checklist or Protocol for Direct Transfer of Care from Procedure Room to Intensive Care Unit (ICU)
  • MM17 – Rate of Witnessed Gastric Aspiration
  • MM18 – Unplanned Conversion to General Anesthesia from Regional or MAC for all scheduled cases

This is unfortunate for anesthesia, as these measures were widely reported; however, they did not show the level of quality differentiation that CMS was looking for.  CMS states that if the average performance rate is above 95 percent, then the measure will be considered for exclusion.  This approach presents a difficult challenge for anesthesia, as the specialty is considered to be one of high quality that delivers a large proportion of care in a high acuity environment. However, collaboration among the anesthesia registries may ease the specialty’s burden in the long run.

What Quality Measures Can Providers Report in 2019?

As the QCDRs continue to search for the quality measures that will best represent the specialty, the MiraMed QCDR has decided to work collaboratively with the other registries to bring additional measures to its clients.  In some cases, we have licensed measures from other registries or harmonized measures drafted with other registries.  These collaborative efforts allow the anesthesia specialty to work together towards our mutual success. 

The MiraMed QCDR expects to support the following measures for 2019:

Additionally, the MiraMed QCDR will support the traditional MIPS measures such as:

If you are a current MiraMed QCDR client, materials will be distributed to you within the next few weeks that will include details for each measure; however, CMS requires the QCDRs to wait to distribute this material until they have officially approved the measures. In the meantime, to prepare to report in 2019, we recommend reviewing this list to identify the measures that look appropriate for your scope of practice.

Do You Need to Report?

Many providers are questioning if there is a need to report in 2019. While the financial incentives for anesthesia shown on CMS’s MIPS website (, aren’t what you might expect, it is still advisable to report for three main reasons: 1) insurance carriers continue to require it; 2) hospitals and facilities continue to request it; and 3) trend data on your own practice is a valuable asset for organizational reviews.

If you have any questions regarding whether your practice is required to report, please use the participation status lookup on the CMS website ( 

Questions?  Contact This email address is being protected from spambots. You need JavaScript enabled to view it. or the MACRA MadeEasy hotline at (517) 962-7301.


April 21, 2017

Most anesthesia practitioners participating in the Quality Payment Program in 2017 will participate in the Merit-Based Incentive Payment System (MIPS). This eAlert offers a guide for eligible clinicians on how the MIPS composite score will be calculated, including an explanation of the scoring system’s four thresholds, a description of the four categories in which clinicians can earn points and suggestions for optimizing your scoring potential.

The Medicare Access & Chip Reauthorization Act of 2015 (MACRA) marked the end of Medicare payment’s fee-for-service model and the beginning of a performance-based payment system, the Quality Payment Program (QPP).  Understanding how participation in the QPP will impact your payments begins with understanding the scoring system.

Scoring in the QPP is impacted by the eligible clinician’s (ECs) choice of one of two tracks: the Advanced Alternative Payment Models (APMs) or the Merit-Based Incentive Payment System (MIPS).  

This eAlert explains the scoring system for MIPS from a high level, including the following:

  • The scoring system’s performance thresholds, laying out the points needed for positive payment adjustments
  • The categories in which clinicians can score points, including an explanation of the benchmark scoring for Quality that is 60% of the clinician’s score
  • Suggestions for how to plan your MIPS strategy within CMS’s new “pay for performance” model

MIPS’ scoring system is on a scale of 0-100.  The score will impact how the Centers for Medicare and Medicaid Services (CMS) calculates payments, trailing two years. A good score in 2017 means a positive payment adjustment in 2019, and so on.  The MIPS score will be used to calculate payment adjustments on a sliding scale from a 4% positive or 4% negative payment adjustment based on 2017 scores (paid in 2019) ramped up to +/- 9% scored in 2020 and paid in 2022.  Payment adjustments will be on a linear scale, so every point earned will mean a larger reimbursement.

Four Scoring Thresholds

The MIPS scoring system has four distinct thresholds.  As 2017 is the transition year for clinicians to join the new program, CMS has tried to make the scoring system as friendly as possible to those just beginning to participate in MIPS.  Not participating at all means a score of zero points, but even modest participation will translate to a score above the positive payment threshold of three points, thereby reaching the neutral payment adjustment.

  • 0 Points: Clinicians who do not participate in MIPS at all will receive zero points and a negative 4% payment adjustment.
  • 3 Points: Even modest participation in MIPS, commonly called the “test pace” option, will earn three points and qualify for a neutral payment adjustment (neither a positive nor negative change in payment).
  • 4–69 Points: This is the range where clinicians can begin to see modest payment adjustments.  Positive payment adjustments will be assigned on a linear sliding scale, with higher scores bringing clinicians closer to the maximum 4% positive payment adjustment.
  • 70–100 points: This group is eligible for the exceptional performance bonus, which will use additional funds to boost positive payment adjustments for top performers.

These thresholds will change in subsequent years, but during the 2017 transition year, the QPP provides a large range of positive payment adjustments for enrollees who earn between 4 and 100 points.

The sliding scale for payment adjustments will depend on several factors, ranging from the available money retained in negative payment adjustments to the scores of participating clinicians.  CMS will take scores in the 4-100 range and apply an adjustment factor that takes these factors into account.  For those scoring in the exceptional performance range of 70-100 points, additional funds are available for a minimum 0.5% performance bonus, possibly scaling as high as a 10% bonus.

Four Performance Categories

In order to earn points, ECs can choose to participate in MIPS' four performance categories: Quality, Improvement Activities, Advancing Care Information and Cost.  The amount that each category contributes to the MIPS final score will change over time, but in 2017, Quality comprises 60% of the MIPS score, Improvement Activities 15%, Advancing Care Information 25% and Cost 0% (to ease the transition to MIPS).  The methods to earn points in each category are unique:

  • Quality (60%): the Quality category is scored by reporting on six quality measures for the full reporting period.  For at least half of the episodes in the reporting period, ECs need to record their performance. (In future years, this reporting rate will increase.) Those of you who have participated in past CMS programs will recognize this as the successor to the Physician Quality Reporting System (PQRS).
  • Improvement Activities (15%): Reporting Improvement Activities requires selecting activities from CMS’s list, which contains over 90 options.  Each activity is either a high or medium "weight," and ECs will need to attest to CMS some combination of four mediums, two highs or a high and two mediums.  Some groups can earn double points, reducing the number of activities they need to attest to for full credit.
  • Advancing Care Information (ACI) (25%): To participate in this category, ECs or groups must complete four or five base requirements with a 2014 or 2015 Certified Electronic Health Record (EHR), respectively.  ECs may then score additional performance and bonus points.  ACI’s component measures will be familiar to those who have participated in the Meaningful Use or EHR incentive programs, but ACI's modular scoring and greater flexibility are different from those programs.
  • Cost (0%): The Cost category measures resource use, and is the only category that does not require ECs to report anything.  In 2017, CMS will calculate Cost scores from submitted claims. CMS will give ECs feedback through the Quality and Resource Use Reports (QRURs), which were previously used as individualized feedback for the Value Based Modifier.

CMS intends to adjust the score weights and nature of these categories every year to adapt to providers’ changing performance.  In 2017, the transition year, CMS has tried to make scoring points as achievable as possible by weighting the categories toward familiar activities (such as quality reporting).  CMS has also tried to provide accommodations for non-patient facing and hospital-based providers and providers in rural or small settings.  Finally, for 2017 only, providers only need to participate for 90 days to be eligible to score in the 4-100 point range.  Earning a positive payment adjustment for 2019 is achievable, with the right registry, EHR and management approach and as long as you are registered and begin collecting data by October 1, 2017.

Most category scoring has a direct relationship between a provider or group's performance and the score earned.  For instance, Improvement Activity scoring is based on a simple attestation: if you perform the activity, you have earned the points.  However, the Cost category (in future years) and the Quality category both have competitive or relative scoring methods.  In 2017, the Quality category's performance scoring method is important to fully understand, since Quality makes up fully 60% of the final MIPS score.  The category's performance scoring system is based on benchmarks derived from previous years' performance data.

In the Quality category, the scale for scoring points varies by measure because each measure has its own benchmark.  An individual quality measure has a scoring potential of 0-10 points.  To assign points, CMS looks at historical performance on that quality measure to establish benchmarks.  The top 10% of a benchmark will earn 9-10 points, the next 10% will earn 8-9 points and so on.  This decile scoring system means that it is possible to perform 95% on a quality measure, but if that is only "average" for the measure (the middle 50% of people reporting that measure had 95% performance), then CMS will award only five points for a 95% score.  Think of this as the equivalent of "grading on a curve."  For measures with very high historical performance, performance rates are so high that only perfect performance can earn the full points, and even 99% performance may only equate to four or five points (CMS refers to these as "topped out" measures).

Optimize Your Scoring Potential

While the Quality category has high standards for benchmarked measures, nearly half of all quality measures do not have benchmarks.  For quality measures without a benchmark, CMS has established a "floor" of three points (out of 10) for measure scores.  This means that, in 2017, it is possible that anesthesia providers selecting measures applicable to their practice may have no applicable measures with benchmarks.  If no submitted measures have benchmarks, a provider's Quality category score will be 18 out 60 points.  CMS will be working to benchmark measures for future years, but in this transition year, many quality measures will only have a three point (out of 10) scoring potential.  To review this year's benchmarks, visit the QPP site's Education page to download the Quality Benchmarks.

QPP Education Page:  
Quality Benchmarks:

Anesthesia providers wishing to maximize their Quality performance score have some options to increase their Quality category scoring potential.  First, they should work with a specialty registry to help select measures applicable to their practice and take care to consider measures with benchmarks (there are some anesthesia-specific measures with benchmarks).  Secondly, providers should consider submitting as many outcome and patient experience measures as possible.  There are many outcome measures in anesthesia, and each measure submitted past the first required measure is worth two bonus points.  Although capped at 10%, ECs can even submit additional measures past the required six measures to earn the bonus points for supporting high priority measures.

The Quality category reveals CMS's general MIPS strategy.  The MIPS scoring system is designed to reward ECs who are deliberate in strategizing about how to improve patient care over time.  Providers who seek high priority measures focused on patient outcomes and experience will earn higher scores.  By incentivizing these activities, CMS hopes to help providers improve their care.

For the overall MIPS score, CMS has set the performance threshold at only three points for the QPP’s transition year.  They will raise the minimum next year (increasing the number of ECs who will receive a negative payment).  In subsequent years—2019 and beyond—the performance threshold will be the mean or median score, as required by MACRA.  Ultimately, a higher minimum performance threshold will mean larger rewards for good performance and deeper negative payment adjustments in the coming years.  The best way to prepare is to start participating now, and to develop a meaningful strategy to ensure the highest quality care.

Questions?  Contact This email address is being protected from spambots. You need JavaScript enabled to view it. or the MACRA MadeEasy hotline at (517) 962-7301.