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POSTS BY TAG | cms regulations


We can all agree that 2020 has been a unique year for all of us. As things change and shift, many things do still remain the same, including MIPS reporting! We’ve made it to the halfway point of the year, trying to figure out the new normal and what business-as-usual looks like, which may leave you with a fuzzy memory that quality reporting may still need to be completed this year.  

As a qualified MIPS registry, pMD has been keeping an eye on the changes and requirements for reporting in 2020. We continue to offer our customers the tools to submit their 2020 MIPS data to CMS and navigate some of these changes using our robust dashboard and excellent account management.

The Elephant in the Room


Do you have to submit MIPS this year in the midst of a pandemic? Maybe.

Other quality programs have previously released amendments to decrease the amount of data submitted to ease the reporting burden during the first and second quarter of this year. However, for MIPS 2020, eligible providers submitting any of the categories (Quality, Improvement Activities, Promoting Interoperability, and Cost) still have the full year’s worth of reporting on the table and there are no changes to the measure requirements. 

The QPP did include a new Improvement Activity to give credit to organizations that participate in COVID-19 clinical trials and offered a complete solution to that performance category:

“Clinicians could also pair the new COVID-19 clinical trials activity with the existing Participation in a 60-day or greater effort to support domestic or international humanitarian needs (IA_ERP_2) activity for full credit for the Improvement Activities performance category.”

For practices affected by the pandemic, you can apply for an exemption to re-weight Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories to 0%. You can find the application and additional information here. CMS will provide the determination of your application via email to the email address you list on your application. 

Changes to Scoring


MIPS Year 4 is turning up the heat for additional data and higher scores.  We are met with increased data reporting requirements in two categories and a 50% increase in final score to avoid a negative payment adjustment.

1) Quality measures must meet 70% of data completeness this year. 
2) Improvement Activities must apply to 50% or more physicians within a group to attest.
3) The performance threshold has been raised to 45 points to avoid a penalty and 85 points to get an exceptional performance bonus.  

Changes to Payment Adjustments


Speaking of payment adjustments, the maximum penalties have been increased again this year.  Clinicians who fail to sufficiently report MIPS are subject to a penalty of up to -9% payment adjustment on Medicare Part B FFS payments. Since the MIPS and MACRA programs have budget neutrality requirements, the rates for positive payment adjustments depend on national submission performance and will be scaled and distributed appropriately. Essentially, the money CMS can pay out to Medicare Part B FFS claim bonuses depends on the number of clinicians who do not submit or perform poorly.


A full list of changes to the Year 4 Final Rule and the most up-to-date information can be found on the QPP website

We are accepting new practices to report MIPS with us in 2021, feel free to take a look at what we offer for MIPS reporting here or give us a call at 800-587-4989 x2. We’d love to hear from you!

To find out more about pMD's suite of products, which includes our charge capture and MIPS registrysecure messagingclinical communication, and care navigation software and services, please contact pMD.
Interoperability of health data


 

HERE’S WHO DID WHAT TO ME: COMING REGULATIONS SUPPORTING INTEROPERABILITY FOR HEALTH DATA


With the creation of MyHealthEData, and through current rulemaking, the Centers for Medicare and Medicaid Services (CMS) is pushing significant new data-sharing requirements into the market.  The new rule opens all types of doors in its effort to improve data transparency and data velocity throughout the system.

The core tenets are:

Ensuring patients have access to all health data where CMS has programmatic authority:


Any payors involved in the following programs are required to have open APIs (Application Program Interfaces): MA organizations, Medicaid programs (both FFS and managed care), CHIP (including FFS and managed care), and QHP issuers in FFEs.

These open APIs will allow patients to empower a vendor to access their claims, encounter data, utilization history, and any clinical health information (such as lab results when available) the payor may have. Payors are also to make their plan directory available through these APIs and have to share care coordination data with each other.

Electronic patient event notifications:  


As a condition of participating with Medicare and provided their EHR has the ability to produce and send an Admit/Discharge/Transfer (ADT) message, it is being proposed that hospitals should send notifications to those practitioners or providers that have an established relationship with the patient relevant to his or her care. (The requirement is waived if the receiving provider can’t receive such messages.)

Prevent information blocking:  


Providers who are not making patients’ clinical data readily available will, essentially, be publicly shamed into compliance as CMS aims to share provider attestations that the provider complies (or doesn’t) with interoperability requirements laid out in updated MIPS rules.  In my opinion, this is a seemingly weak penalty for non-compliance so hopefully, CMS tightens this to improve accountability.

So how might care be impacted by these changes if implemented largely as proposed?  


Where are patients likely to engage with this information?  How about providers?

Patients, to date, have shown little interest in actively engaging with their health care data on their own (consider almost every provider’s struggle to get Portal engagement) - what will Medicare/Medicaid patients do with their claims history?  It’s possible applying algorithms to claims data to identify at-risk profiles might generate patient-level demand but the marketing will have to be focused and on point.  

The first real-world test of the data typically available is Medicare’s Blue Button API (now in version 2.0).  As of October, there were 1,200 software developers in the sandbox and 100 - 200 patients had downloaded their data.  It’s possible this gap between developer engagement and patient engagement represents a lag from the time it takes to create an application to generating demand for the information.  I think it also highlights that age-old health care problem of an abundance of data and little of it valuable or comprehensible to your average individual. At the end of the day, how do you engage a patient to make their best health care choices when those choices are either deeply complex or rarely and erratically occur?

The other audience, of course, is providers.  Claims data provides a history of activity which can complement the clinical care history each participating provider can access.  They can see diagnoses and procedures which both carry useful information in any given provider’s ongoing care of the patient and supplement their clinical inquiries.

The second benefit of having access to claims data is in optimizing HCC scores.  Since a primary input of HCC scores are all the diagnoses a patient accumulates during the year, having access to a comprehensive list of billed diagnoses allows for any given provider to potentially optimize the patient’s HCC scores.  If this market evolves, payors could fully decentralize HCC scoring (with appropriate incentives) to providers. Considering the HCC score paradigm is national, and zero-sum, it can be expected there will be a rush to claim this space and a handful of winners should emerge.

The health care market continues to be pushed to evolve as the population ages and inflation marches on.  You should consider the technology companies you work with and ask if they have the history, the people, and the capabilities to help you navigate a market where changes can dramatically impact your bottom line and your outlook.  At pMD, through our expertise in mobile charge capture, secure clinical communications, and care navigation we strive to meet our customers where their future needs live.  See what we are about at www.pmd.com.

Related Articles:

Interoperability in Health Care IT: The New Norm… Eventually
The Goal of Interoperability in Health Care: Uniting People & Systems


To find out more about pMD's suite of products, which includes our MIPS registrycharge capturesecure messagingclinical communication, and care navigation software and services, please contact pMD.