2020 MIPS & FAQs - QPP Resource Center...2020/07/30 · Page Header © 2018 Purdue University 2020 MIPS & FAQs July 30, 2020 Merit-Based Incentive Payment System Lunch and Learn Page

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© 2018 Purdue University

2020 MIPS & FAQs

July 30, 2020

Merit-Based Incentive Payment System

Lunch and Learn

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2© 2018 Purdue University EA/EOU

Presenter

Senior Quality Advisor

Purdue Healthcare Advisors

Jennifer Anglin MS, CHES,

PCMH CCE

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Agenda

1) Overview of MIPS

2) Promoting Interoperability

3) Quality

4) Improvement Activities

5) Cost

6) Submission, Hardships & Documentation

7) Q&A


▪ Have you submitted MIPS before?

▪ Are you a small practice (15 or fewer providers)

or large (over 15 providers)?

Who Is Out There?

Please let us know using the chat feature

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Overview of MIPS


Low-Volume Threshold

Meet all three to be an EC

Bill Medicare Part B more than $90,000 annually in allowed charges for covered

professional services under the Medicare Physician Fee Schedule

AND

Provide care for more than 200 Medicare Part B patients a year

AND

Provide 200 or more covered professional services to Medicare Part B patients

Determination snapshots that you must meet

thresholds for in order to be an EC:

Oct. 1, 2018 – Sept. 30, 2019

AND

Oct. 1, 2019 – Sept. 30, 2020

Final determination published in November


Check The QPP Site For Eligibility

https://qpp.cms.gov/participation-lookup

https://qpp.cms.gov/participation-lookup


▪ This provider is not eligible to submit as an individual

▪ This provider is eligible to opt-in as an individual

▪ This provider is eligible to submit as a group (ECs in TIN)

– Not required to submit as a group

What Can You See in the Look-Up?


More Good Information To See

Click on + Expand


Special Status Definition Effect

Ambulatory Surgical

Center

75% of services at POS

24

Automatic reweighting

of PI to 0%

Hospital-Based 75% of services at a

hospital (POS 19, 21,

22, or 23)


of PI to 0%

Non-Patient Facing Indiv. -100 or fewer

patient-facing

encounters OR Group -

75% EC in group are

non-patient facing

IA points are doubled

AND


of PI to 0%

Small Practice 15 or fewer clinicians in

TIN


AND

6 bonus points added

to Quality if at least 1

Quality measure

submitted

Automatic Special Statuses


Special Status Definition Effect

HPSA Designated as a HPSA IA points are doubled

Rural Designated as Rural

from zip code


Extreme and

Uncontrollable

Circumstances

(Individual only)

**This is different than

the hardship you can

apply for COVID-19,

vendor issues, etc.

CMS declared – such

as FEMA designated

disaster area

All categories

reweighted to 0%

Automatic Special Statuses


What If You Are Not An EC?

But, you have good data to submit!

Opt-In Voluntarily Submit

Must meet 1 or 2 of the low-

volume thresholds

No requirements

Subject to payment adjustments

(negative, neutral, positive)

No payment adjustments

Feedback from CMS Feedback from CMS

Yearly option Yearly option

Once opted-in, you are locked in

to that decision for that year


2020 Category Weights

Remain the same as in 2019

Calculations result in a score from 0-100


2020 Payment Adjustment Thresholds

0

45

100

Negative 9% PaymentAdjustment

Neutral Positive Payment Adjustment

85

0 - 11.25 points = -9% payment adjustment

11.26 – 44.99 points = Negative payment adjustment (>-9% to


▪ You may submit group AND individual

– CMS will take higher score

▪ Benefits to group reporting

– Lower performers will benefit from higher performers

▪ By high performers submitting individually in addition to group, CMS will

award them the better of the two scores

▪ Recommendation is to report as a group (unless less than 45 points), then

have providers who scored higher than the group score submit as individuals

– Make sure they are eligible to report as a group!

Individual & Group Reporting

Or both!

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Promoting

Interoperability


BREAKING NEWS!

Direct Messaging Requirement

CMS and ONC now mandate a centralized directory of provider electronic

addresses for data exchange.

The National Plan & Provider Enumeration System (NPPES) will be the database

to make digital contact information searchable and publicly available and to

advance national goals for promoting interoperability.

Failure to enter your Direct Message address into NPPES will result in the

inability to pass the Information Blocking section of PI.

Please enter your Direct Message address in NPPES as soon as possible!

https://npiregistry.cms.hhs.gov/

https://chitrec.us1.list-manage.com/track/click?u=d96a7be4b16317a6d82d75443&id=e1176b1227&e=21a07ebaa9https://npiregistry.cms.hhs.gov/


▪ Query of Prescription Drug Monitoring Program (PDMP) still bonus

▪ Removal of bonus objective Verify Opioid Treatment Agreement

▪ Threshold to be considered a hospital-based group reduced from 100%

to 75%

– Why is this important?

– Hospital-based groups are automatically exempt from reporting

Promoting Interoperability (0% weighting)

Not Many Changes

Still a minimum of 90 continuous days reporting period


Measures Weight

Security Risk Analysis

E-Prescribing Up to 10 points

Bonus: Query of Prescription Drug Monitoring

Program

5 bonus points

Provide Patients Electronic Access Up to 40 points

Support Electronic Referral Loops by Sending

Health Info

Up to 20 points

Support Electronic Referral Loops by Receiving

and Incorporating Health Info

Up to 20 points

PI Measures for 2020


Measure Weight

Public Health and Clinical Data Reporting

(Choose 2 of 5 Options – Immunization,

Syndromic Surveillance, Clinical Data, Case

Reporting, Public Health)

10 points for 2

(Yes-Yes or Yes-Exclude)

PI Measures for 2020

Must register within 60 days

after the start of your

reporting period. The last

day would be December 2.Need a registry?

*Check with your vendor

*Check with your professional society

*Are you (f)(7) certified? CDC’s

National Health Care Survey program


Exclusions

Reallocation of points

Exclude From Points Reallocated to

eRx (less than 100 prescriptions) 5 points to HIE sending and

5 points to HIE receive and incorporate

Patient Electronic Access No exclusions!

HIE Sending (less than 100 referrals) 20 points to patient electronic access

HIE Receive/Incorporate (less than

100 referrals)

20 points to HIE sending

Public Health/Clinical Data Registries

(2 exclusions)

10 points to patient electronic access

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Quality


▪ 218 total quality measures (47 eCQMs, 55 claims)

▪ Report a minimum of 6

– 1 must be outcome or high-priority (if no outcome available)

– You may choose a specialty-specific measure set

• Some have fewer than 6 (it’s ok, but you must report all of them)

• New specialty sets have been added in 2020!

Not Much Has Changed

Full calendar year for reporting period


Quality

Data Completeness & Bonus Points

• Data Completeness

• Thresholds increased to 70%

• This means Quality measures will need to be reported on at least

70% of eligible cases for the entire year.

• Claims submissions = Part B claims only

• Other submission methods = all-payer claims

• Bonus Points

• 2 points for each additional outcome or patient experience measure

• 1 point for each additional high-priority measure

• 1 point for each end-to-end submission (electronic and not

manipulated)

• Bonus points capped at 10% of denominator

• 6 bonus points for small practice (must submit minimum of 1 quality

measure)


Getting the Most Points - Benchmarks

Why is submission method important?

60%

80%

In QPP Resource Guide

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Improvement Activities


▪ 105 Improvement Activities (IA) to choose from

▪ 40 points possible

▪ Small practice (15 or fewer providers), rural, HPSA, and non-patient

facing clinician weights

▪ Medium: 20 points

▪ High: 40 points

▪ 2 medium or 1 high for full points

▪ Large practice weights (more than 15 providers)

▪ Medium: 10 points

▪ High: 20 points

▪ 4 medium, 2 high, or 2 medium + 1 high for full points

▪ Need to be working on IA at least 90 continuous days


15% of final score



IA Validation Sheet

PHA can provide

the validation

sheet broken

down by topic!

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Cost


▪ Calculated by CMS on your administrative claims

▪ Total Per Capita Cost (TPCC)

▪ Medicare Spending Per Beneficiary - Clinician (MSPB-C)

▪ 18 episode-based measures (8 in 2019)

Cost

15% of total score

Click Here for Cost Guide

https://qpp-cm-prod-content.s3.amazonaws.com/uploads/965/2020%20Cost%20Quick%20Start%20Guide.pdf


Cost Category Updates

▪ If case minimums aren’t met, 15% for Cost is reallocated to Quality (45% to 60%)

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Submission,

Hardships, &

Documentation


▪ You may submit via different methods

▪ CMS will take your higher submission

Submissions

Promoting

Interoperability

Quality Improvement

Activities

Cost

Minimum 90

continuous days

Full calendar

year

Minimum 90

continuous days

Full calendar

year

QRDA III upload

to QPP portal

Medicare B

Claims

QRDA III upload to

QPP portal

No submission –

CMS calculates

Manual entry in

QPP portal

eCQMs (from

EHR as a QRDA

III file)

Manual entry in

QPP portal

Registry MIPS CQMS

(Registry)

Registry


▪ Automatic reweighting for specific clinician types

– Non-patient facing

– Hospital-based

– ASC-Based

– PA

– NP

– CNS

– CRNA

– PT

– OT

– Clinical Psychologist

– Speech-language pathologist

– Audiologist

– Registered Dietician or Nutrition Professional

Exemptions for Promoting Interoperability

PI = 0% and Quality = 70%

Submitting PI data will override

this automatic reweighting! So,

submit if you have good data!


▪ Application-based reweighting for specific situations

– Small practice (15 or fewer Medicare billing clinicians)

– Decertified EHR

– Insufficient internet connectivity

– Extreme and uncontrollable circumstances

– Lack control over availability of CEHRT

▪ Application available now on the QPP website (will need login

credentials).

Exemptions for Promoting Interoperability

PI = 0% and Quality = 70%

Submitting PI data will override

this automatic reweighting. So,

submit if you have good data!

This is a great “safety net” to

have in place!


Extreme & Uncontrollable Circumstances Hardship

Manual application

• Log into the QPP portal to apply

• Available now – December 31, 2020 (8:00 PM EST)

• Must provide justification as to why applying for hardship

• CMS will notify you if approved or not

• May apply for 1 to 4 categories to be re-weighted to 0%

• If you submit, hardship overridden for that category

• Great safety net!

You experience an extreme and

uncontrollable circumstance outside of

your control, such as a natural disaster or

public health emergency (e.g. COVID-19

pandemic), that prevents you from

collecting data for an extended period of

time, or that could impact your

performance.

Resource Library - 2020 Exception Application Fact Sheet

https://qpp.cms.gov/about/resource-library


If Approved for EUC Hardship…

• Submit 0 or 1 category = neutral payment adjustment

• Submit 2 or more categories = negative, neutral, or positive payment adjustment

Watch out for

claims

submissions! If

there is even one

claims submission,

the Quality

category will be

scored and

override the

hardship.


Mid-Year EHR Switch

We changed EHRs in the middle of the year!

Category

PI 90 continuous days of data only! Choose a 90 continuous days

that best suits you. If need be, aggregate data from both EHRs

and submit as a single n/d

IA 90 continuous days of data only!

Cost Not affected

Quality 365 days of data.

You will need to aggregate data from both EHRs and submit a

single submission. If aggregation is NOT possible, CMS still

requires data completeness threshold of 70% for entire year.

Talk with your PHA advisor about MIPScast©


▪ Promoting Interoperability

– Report from EHR

– Security Risk Assessment

– Proof of Registries

▪ Quality

– Report from EHR

▪ Improvement Activities

– Proof of implementation

▪ Cost

– Nothing

▪ Submission receipt from registry or QPP Portal

Documentation

Keep 6 years minimum

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Recap of Main Points1) Choose Quality measures that are

pertinent to your patient population

2) Choose IAs pertinent to your patient

population and start early

3) Run reports often1) Start running reports as soon as possible

2) Do you believe the numbers?

1) If not, investigate early

4) Celebrate even the small successes!

Documents

2020 MIPS & FAQs - QPP Resource Center...2020/07/30 · Page Header © 2018 Purdue University 2020 MIPS & FAQs July 30, 2020 Merit-Based Incentive Payment System Lunch and Learn Page