MIPS Improvement Activity: Patient-Centered Medical Home

Is your practice a recognized Patient-Centered Medical Home (PCMH) or considering the transformation process?

Currently, over 1,300 practices in New England are recognized as PCMHs or comparable specialty practice programs by the National Committee for Quality Assurance (NCQA). Further, PCMH recognition is aligned with the Merit-Based Incentive Program (MIPS) and provides an opportunity to receive automatic credit.

The principles of PCMHs and Patient-Centered Specialty Practices (PCSPs) focus on:

  • Team-based Care
  • Quality Improvement
  • Care Coordination
  • Care Management
  • Patient-centered Access
  • Population Health Management

These principles provide a roadmap for practices to transform into medical homes, but are not intended as “one size fits all.” Primary care practices of all sizes and settings are eligible to transform into PCMHs. PCMH eligible clinicians include physicians, physician assistants, and nurse practitioners.

How does PCMH or PCSP recognition align with MIPS?

When it comes to MIPS, PCMH or PCSP recognition from an accredited body will automatically earn a practice full credit – or the highest potential score – toward the Improvement Activities performance category. In the 2017 Transitional Year, the Improvement Activities category is weighted at 15% of the total MIPS score. This means that PCMH or PCSP recognition will earn a MIPS eligible clinician or group 15 points toward their total MIPS score.

As stated in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Final Rule, a PCMH or PCSP must be recognized by a nationally accredited organization. These organizations include:

  • The National Committee for Quality Assurance (NCQA)
  • The Joint Commission Designation
  • the Utilization Review Accreditation Commission (URAC)
  • The Accreditation Association for Ambulatory Health Care

Becoming a PCMH or PCSP involves submitting to the accreditation body various forms of documentation, such as written policies and procedures, screenshots and reports from the electronic health record system. In turn, the recognition process prepares practices for the other MIPS performance categories. PCMH and PCSP practices review and act to improve performance data that align with MIPS Quality and Advancing Care Information categories. For example, practices working on PCMH recognition are required to submit data on preventive and chronic care measures that are relevant to the practice, and identify opportunities to improve performance.

Keep Your Practice Recognition Materials

A simple attestation is required to submit for the MIPS Improvement Activities category. However, if you are recognized as a PCMH or PCSP, remember to hold on to your practice’s recognition materials from NCQA or other applicable accreditation body. CMS denotes either of the following as suggested supporting documentation in the event of an audit:

  1. Documented implementation of patient-centered medical home activities and improvements that pertain to care coordination, patient-centeredness, or comprehensiveness of care, among others; or
  2. Documented recognition as a patient-centered medical home from accredited body, combined with continual improvements

Recognition Deadline

It is important to note that an eligible clinician or group must receive PCMH or PCSP recognition no later than October 1, 2017 in order to receive full credit on Improvement Activities in the MIPS Transition Year. The eligible clinician or group must be able to report a continuous 90-day period as a PCMH or PCSP.

Is Your Practice Reporting MIPS as a Group?

If there is one practice within a group Tax ID number (TIN) that is a recognized PCMH or comparable specialty practice, the whole TIN will receive the highest potential score for the MIPS Improvement Activities. CMS does not specify a threshold for the number of practice sites under one TIN that must be PCMH/PCSP recognized in order to receive full credit. However, please note that CMS may change this rule in future years of the MIPS program.

Not a PCMH or PCSP? No problem, there are over 90 Improvement Activities to choose from. Please visit the list of Improvement Activities on the CMS Website or view the our MIPS Improvement Activities webinar.

Sources:

  1. CMS Final Rule
  2. NCQA.org
  3. MIPS Data Validation Criteria Excel File

Questions?

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