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Responses/Clarifications for Anchor Questions on Updated PFM
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• Events
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Responses/Clarifications for Anchor Questions on Updated PFM
May
26
Cross-regional Performing Providers
The “home” regions selected by cross-regional providers is indicated in the Minimum Point Thresholds file and will be included in the RHP Plan Update templates.
Providers will only need to submit information in the RHP Plan Update in their “home” region.
Performing Providers that were moved to “home” regions do not need to apply measure bundle points proportionally to each region they previously participated in.
These providers will be required to continue DSRIP activities (includes Category A-D) in the previous regions as certified in the RHP Plan Update and summarized qualitatively during Category A reporting.
Measure bundles and MLIU PPP overlap
For situations where multiple Performing Providers are serving the same patients and want to select the same measure bundles, HHSC is still working on how to help different providers that share the same location define their system -- this most specifically applies to physician groups associated with an Academic Health Science Center
that may not have their own hospital.
While we encourage collaboration between these providers, and choosing some of the same measure bundles will be allowed, the system definition for these providers may not be one and the same. In other words,
the system of one performing provider may not be exactly the same as a second performing provider.
Some overlap may be permissible.
Carryforward
There are two types of carryforward: 1) carryforward of reporting and 2) carryforward of achievement.
Neither types of carryforward apply to Category A or Category D.
Carryforward of reporting
is allowed for:
Category B - MLIU PPP may be reported in October of the current DY or April of the following DY with the same measurement period, e.g., DY7 MLIU PPP may be reported in October DY7 or April DY8 with the measurement period as DY7.
Category C - P4R Measures may be reported in October of the current DY or April of the following DY with the same measurement period, e.g., DY7 P4R measure may be reported in October DY7 or April DY8 with the measurement period as DY7.
Category C - P4P Measures with calendar year (CY) measurement periods may report baselines and performance in one of two reporting periods - the one immediately following the measurement period or the following reporting period, e.g., Baseline of CY17 may be reported in April or October DY7 while DY7 achievement of CY18 may be reported in April or October DY8.
Carryforward of achievement is allowed only for Category C - P4P measures
DY7 goal achievement may be achieved in PY1/CY18 or PY2/CY19. Carried forward DY7 PY2 achievement must be reported in April DY9.
DY8 goal achievement may be achieved in PY2/CY19 or PY3/CY20. Carried forward DY8 PY3 achievement must be reported in April DY10.
RHP Plan Update
HHSC has not developed the RHP Plan Update template; however, it will likely be an
Excel template per Performing Provider that auto-populates information such as valuation, checks inputs, allows limited requests for changes as specified in the PFM
, etc. Depending on CMS approval of the additional 21 months and protocols, the t
emplate is tentatively targeted for release in December 2017.
Providers do not need to indicate in the RHP Plan Update whether they plan to report Category C - P4P measure baselines in April or October DY7.
Baseline performance does not need to be submitted with the RHP Plan Update
as it is included under the DY7 baseline reporting milestone.
If providers are requesting shorter or delayed measurement periods, they are planned to be submitted in the RHP Plan Update.
Anchors will not be required to maintain updated RHP Plan Updates incorporating HHSC/provider changes to Categories A-D. Future changes (after RHP Plan Update submission) will be incorporated in the DSRIP Online Reporting System and HHSC posted materials.
Providers that previously indicated their request to increase their valuation to $250,000 in the DY6 Participation Template do not need to re-request the increase. All Performing Providers will be required to certify their DY7-8 valuation in the RHP Plan Update.
Category C - P4P Measures
A provider may be approved to be exempted from reporting performance on the Medicaid-only payer type and/or the LIU-only payer type for a measure’s reporting milestone; however, the provider is still required to report performance on the all-payment type at a minimum to eligible for payment of the reporting milestone.
HHSC is working to align measure bundles with MACRA/MIPS and MCO quality measures.
Rural hospitals may select the same measure bundles and must report on all the required measures within a selected measure bundle. There may also be optional measures in a measure bundle.
There is not a maximum valuation for Measure Bundles with standalone measures. There is a
maximum for Measure Bundles with only non-standalone measures
and a minimum valuation for all Measure Bundles as described in PFM paragraph 17.h.
All measurement periods must be consecutive, e.g. for measures with approved shortened or delayed baseline measurement periods, the 12 months immediately following the baseline period would be the performance year.
Minimum Point Thresholds
Regarding PFM paragraph 17.k.iii. that hospitals for which HHSC did not have sufficient data or specialty hospitals with limited scope may have an alternate methodology for determining their MPTs, HHSC has not notified those hospitals or determined a calculation methodology yet.
The steps in calculating each hospital MPT is described under PFM paragraph 17.k.ii. and formulas were included in the “Minimum Point Thresholds” file that was shared with Anchors on 5/17/17. In summary, first the Statewide Hospital Factor (SHF) is determined, next the Statewide Hospital Ratio (SHR) is determined, and then based on the SHR, the MPT is determined as described in PFM paragraph 17.k.ii.C.
Reporting: If a Performing Provider does not complete Category A DY7 reporting in October DY7, then they may be subject to recoupment of all DY7 payments from April DY7 including the RHP Plan Update payment and the related October DY7 payments would be withheld.
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