MIPS Post-COVID Reset – the Nuts & Bolts

Nancy Nelson, Senior Consultant Healthcare Consulting

MIPS quality data and reporting for CMS reimbursement is yet another aspect of our industry that has been disrupted and changed by the COVID-19 pandemic. In fact, COVID exploded onto the scene just as practices were preparing to submit their MIPS data for the 2019 Performance Year by the March 31, 2020 deadline.

The first change this spring came on March 22, 2020, when CMS announced it would help providers by delaying the MIPS annual reporting deadline another month, from March 31 to April 30. CMS also decided that “MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 will qualify for the automatic ‘extreme and uncontrollable circumstances policy’ and will receive a neutral payment adjustment for the 2021 MIPS Payment Year” (as opposed to a possible penalty of up to 9% for failing to report).

So, the ship has sailed on reporting of 2019 data. Now, we turn to the current 2020 Performance Year, presumably to be reported next March (2021). Clearly, some allowances will be made at least for the March-May period at the height of the pandemic; CMS has said that it “is evaluating options for providing relief around participation and data submission for 2020.”

Now that the pandemic shows encouraging signs of receding and medical practices have shifted to carefully phased re-opening, a key task (among many) is to get back on top of quality scoring measures, including MIPS – which makes it a good time for a re-education on the “nuts & bolts” of MIPS and how it works.

MIPS Historical Timeline

It has been over a decade since the ideology of value-based care was presented in its infancy stage. The federal government passed Medicare Improvements for Patients & Providers Act (MIPPA) in 2008 and following close behind was the Affordable Care Act (ACA) in 2010. The Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) initiated the Merit-Based Incentive Payment System (MIPS) which is the current program clinicians have been participating in since 2017.

These new laws were established in hopes of avoiding large decreases in physician reimbursement, which were in part projected due to increased utilization. The intent of the new legislation was to shift gears from the traditional fee-for-service (FFS), a quantity-based payment model, to a value-based payment model. The value-based model rewards clinicians for high value and high-quality patient care, which is measured by patient health outcomes.

The Big Picture of MIPS

As the model for value-based care has evolved, the government continues to update and make improvements to reduce the burden placed on clinicians to meet the requirements to successfully attest. Old programs such as Medicare Electronic Health Records Incentive Program for Eligible Clinicians (aka “Meaningful Use”), Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VBM) have been consolidated into the current day program called MIPS.

The current performance in MIPS is measured in four categories:
1) Quality Measures (45%)
2) Cost Measures (15%)
3) Improvement Activities (15%)
4) Promoting Interoperability Measures (25%)

Without a change in the program due to COVID-19, the Quality Measures and Cost Measures categories were to be measured for a full year and Improvement Activities and Promoting Interoperability Measures categories had a 90-day reporting period. At this time, CMS has not issued guidance on the Quality Payment Program for the 2020 performance period. COVID-19 definitely will have an impact on the requirements; therefore it is critical to stay abreast of those changes put forth by CMS.

MIPS Data Collection Types

All four MIPS categories are equally important when calculating success with MIPS, but we are going to solely focus on the Quality Measures category. The Quality Measures category replaces PQRS. There are 6 collection types for quality measures:

  • Electronic Clinical Quality Measures (eCQMs)
  • MIPS Clinical Quality Measures (CQMs) (more commonly referred to as registry measures)
  • Qualified Clinical Data Registry (QCDR) Measures
  • Medicare Part B claims measures
  • CMS Web Interface measures
  • The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS survey

A few key points when determining which collection type you will use include size of practice, Electronic Health Record (EHR) certification year and measure availability, specialty and scope of practice, vendor fees for reporting and/or interfaces, and participation in a MIPS APM. Clinicians can submit from multiple collection types to satisfy reporting requirements, with the exception of the CMS Web Interface which cannot be combine with other collection types.

Out of the various measures available to report on in 2020, the clinician needs to select 6 measures minimum, with one of those measures being an outcome measure or high priority measure if there is not an applicable outcome measure available. The data completeness criteria is set at 70% of patients who qualify for each reported measure. If a practice does not have a “Small Group Designation” (15 or less providers), CMS will automatically calculate the All-Cause Hospital Readmission measure, which is figured as a 7th measure. Without any indication currently from CMS that there will be exceptions for submission for 2020 data, now is the time to review your processes and ensure you are capturing the necessary quality measures data.

MIPS Data Submission Types

CMS has four different submission types to submit the quality data you have collected. Appropriate submission type varies by who is submitting the data, whether it is the eligible clinician, representative of the practice or APM Entity, or a third-party intermediary.

The submission types include Medicare Part B claims; sign in and upload or attest on the QPP site; CMS Web Interface; or direct submission through Application Programming Interface (API).

MIPS Scoring

There are three components to the quality category when scoring. The first includes 1-10 points for each measure based on a practice’s performance compared to a benchmark. Small practices, (those with 15 or less clinicians), will automatically receive 3 points, whereas large group practices automatically receive 1 point for submitting the bare minimum on a measure. The benchmarks for each measure are presented in 8 deciles, and within each decile there is a performance range. The number of points awarded per measure will depend on what decile position the performance falls into.

Practices need to review which measures would place them in a higher decile. There may be a measure that the overall performance is lower, but the decile placement will score more points due to the overall benchmark. Are you leaving points on the table due to picking the wrong measures to report on?

Clinicians can also earn bonus points, which is the second component of quality scoring. Activities such as submitting an additional outcome or patient experience measure, submitting a high-priority measure, submitting measures electronically, and submitting at least 1 quality measure as a small practice will earn bonus points.

The third component is factored in when improvements have been made from the previous year in your quality performance. Up to 10 additional points can be earned based on the rate of improvement.

Invest in Optimizing Your MIPS Quality Measures

It is critical to invest time to review processes for capturing Quality Measures data available for submission for 2020. The possibility of another “Extreme and Uncontrollable Circumstances” application available to individuals, groups and virtual groups for 2020 data is highly anticipated, but it is imperative to be prepared! Now is a good time to really learn the nuts and bolts of which measures will optimize your Quality score, so when you do need to capture and submit data you can be successful. Medical Advantage has helped practices choose the best Quality Measures which produced optimal results for the MIPS program, we have a team of experts devoted to knowing the ins and outs of the program, and keeping up-to-date on the latest updates from CMS and how to interpret and apply those updates for our clients to achieve optimal results in MACRA/MIPS. Don’t miss updates from CMS or leave points on the table; reach out to Medical Advantage MACRA experts today.

Talk to one of our MACRA experts today