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POSTS BY TAG | Quality Scoring






As we approach the submission deadline for 2018 MIPS reporting and find ourselves in the second quarter of 2019, it’s important to understand the changes that are in store for this upcoming reporting year. As a qualified MIPS registry, pMD gives customers the tools to submit their 2019 MIPS data to CMS and navigate some of these changes using our robust dashboard. As there are a lot of updates to the MIPS reporting requirements each year, I would like to address a few of the many questions that have recently come up.

Changes to Eligibility

In prior years, the list of clinician type has been fairly short to only include physicians, their mid-level providers, and nurses. Starting in reporting year 2019, there are 6 additional clinician types that are now included in MIPS reporting:

Physical therapists
Occupational therapists
Qualified speech-language pathologists
Qualified audiologists
Clinical psychologists
Registered dietitians or nutrition professionals


Find yourself on this list?  There is no need to panic! You can easily check to see if you are required to report based on your Medicare Part B volume by using the Quality Payment Program’s tool: QPP Participation Status

For the first year since the program began, clinicians who were previously ineligible to report can opt-in beginning Year 3. Physicians interested in this must meet at least one of the following criteria and are an eligible clinician type:

1. Have ≤ $90K in Part B allowed charges for covered professional services
2. Provide care to ≤ 200 Part B-enrolled beneficiaries
3. Provide ≤ 200 covered professional services under the Physician Fee Schedule (PFS)

Interested in opting-in to MIPS this year?  Keep in mind that opting-in may be irreversible, but stay tuned for an announcement from CMS QPP on where and how to opt-in later this year!

Changes to Submission

In previous years, claims-based submission was a viable option for many clinicians and organizations to report.  This year, claims submission is only available to small practices who have less than 15 providers. Larger groups may want to look into submitting through a qualified registry, QCDR, or your EHR. Questions about how to submit through a qualified registry? Give us a call at 800-587-4989 x2 to discuss your reporting options!

Individuals, groups, and virtual groups can begin to use multiple submission mechanisms for Year 3 reporting so you are no longer locked in to using just one mechanism or vendor. This change should make it easier for clinicians and health care organizations to leverage the tools they already have to submit different sections of reporting. The QPP has increased their capabilities, allowing the review of multiple submissions, selecting only the highest scores to keep as the final one for determination. In fact, they list out that “if the same measure is submitted via multiple collection types, the one with the greatest number of measure achievement points will be selected for scoring.“

Changes to Scoring

One of the more notable changes to Year 3 is the change to the final score breakdown. The contribution to the final score for the Quality category decreases to 45% and increases to 15% for the Cost category. There are no changes to the contributions of Promoting Interoperability or Improvement Activities categories.





Another change to the Quality category is that the small practice bonus for groups with less than 15 clinicians is awarded to the Quality section so long as there is at least 1 quality measure reported. This differs from Year 2 which awarded the 5 points to the final score total.

Changes to Payment Adjustments

As the QPP rolls out the MIPS program in stages, we will see increased difficulty in obtaining a positive payment adjustment. The first year of MIPS offered a “Test” submission in which by submitting any data, clinicians can easily avoid any penalties.  Last year, clinicians just had to score 15 points to avoid the penalty and be eligible for a positive payment adjustment. Beginning in calendar year 2019 (MIPS Year 3), the performance threshold had been increased to 30 points. Clinicians scoring under 30 points for their MIPS Final Score are subject to a negative payment adjustment. For groups trying to obtain the Exceptional Performance bonus, that threshold was also increased to 75 points.

Speaking of payment adjustments, the maximums have been increased for them as well.  Clinicians who fail to sufficiently report MIPS are subject to a penalty of up to -7% payment adjustment on Medicare Part B FFS payments. On the flip side, the maximum bonus can be up to a positive 7% payment adjustment - however, to keep budget neutrality, it will depend on overall submission performance and will be scaled and distributed appropriately.

A full list of changes to the Year 3 Final Rule and the most up-to-date information can be found on the QPP website.

Questions on your 2019 reporting options?  Feel free to take a look at what we offer for MIPS reporting here, or give us a call at 800-587-4989 x2!

Find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, clinical communication, and care navigation software and services, please contact pMD.


Hello again! As promised, I’m back with more simply explained goodies about MIPS scoring for the 2017 performance year. In Part 1 of this series, we discussed the Basics of MIPS Scoring. That post is chock full of great information (if I do say so myself!) so definitely check it out. In today’s post, Part 2, we’ll cover scoring the Quality category. Then, in Part 3, we’ll discuss scoring for the Improvement Activities category. And finally, Part 4 will cover Advancing Care Information scoring, tying it altogether with an overview of the MIPS payment adjustment calculation. But, first, Quality!

The Basics of Scoring the Quality Category

For most of our MIPS Registry participants, the Quality category feels the most comfortable. Many of the principles we came to learn and love in PQRS hold true in MIPS Quality, so it’s less of a puzzle to figure out. But, there are some important differences, and scoring is one of them. Keep in mind that Quality is worth the largest portion - at least 60% - of the overall MIPS Final Score (a calculation I’ll discuss in Part 4), so if you’re aiming for a positive payment adjustment, this category is an important one to pay attention to.  

For the quality category, each reported measure will receive between 3 and 10 points. In order to be considered to receive more than 3 points, a reported measure must:

1) Comprise of at least 20 reported qualifying events;
2) Have a benchmark; and
3) Meet the data completeness standard.*

*For registry, QCDR, and EHR reporting, data completeness means that measures must be reported on at least 50% of the qualifying events for that measure, based on your entire patient population (not just Medicare Part B FFS patients), and must include at least one Medicare Part B FFS patient.

If any of the above features are missing, the measure will receive 3 points. But, if all the above features are established, the measure can receive up to 10 points. To determine whether more points will be awarded, CMS compares your measure’s performance data to a national benchmark. The benchmarks provide a comparison point to determine if your performance was higher than the national average, thus meriting more points.

You’re probably now wondering: where does the national benchmark data come from? Well, for the MIPS 2017 performance year, the benchmarks are based on 2015 PQRS performance data. Each benchmark is broken down into performance deciles, with the worst performance in deciles 3 and below and the best performance in decile 10. Benchmarks also vary from submission mechanism to submission mechanism. So, there is a different benchmark for EHRs, Registries, QCDRs, etc. You can check out the benchmark data that will be used for the 2017 performance year by going to the QPP website’s resource library and downloading the zip file called “2017 Quality Benchmarks.”

So, this is the basic methodology used to score the Quality category. Ultimately, your score depends on the benchmark, but as a rule of thumb, you want to have the highest possible quality performance to maximize points per measure. Also, note that, unlike PQRS where you received an automatic ding if didn’t fully report, with MIPS Quality, if you report less than 6 measures, and you’ll be scored on whatever is submitted, and receive a “0” score for measures that you could have submitted but didn’t. So, your score won’t be high in this scenario, but it’s not an automatic negative. On the other side of the spectrum, if you choose to report more than 6 measures, your outcomes or high priority measure will be scored, and then the measures with the highest points earned will be used in your score. But, note that all measure results submitted will become public information, so consider your quality reporting strategy carefully before submission.

Bonus Points Awarded in the Quality Category

Before we move on from Quality scoring, there is one more thing you should know. That is, you can receive bonus points in the quality category for two separate reasons. The first is by reporting additional high priority measures, and the second is by reporting measures via end to end electronic reporting.

Bonus Points Earned by Reporting Additional High Priority Measures

The first way to earn bonus points in the Quality category is to report additional high priority measures. But, there are three nuances to earning these bonus points that you should keep in mind:

1) The total amount of bonus points available is capped at 10% of the total points available to the reporter in the quality category. So, this isn’t a huge bonus, but it’s still a bonus!
2) To receive bonus points, you must submit at least the one required, fully reported, scored outcomes or high priority measure. So, make sure at least your first outcomes or high priority measures has 20 cases reported and 50% of all encounters, plus at least 1 Medicare Part B FFS patient.
3) Bonus measures themselves must have at least 20 cases reported and 50% of all encounters, plus at least 1 Medicare Part B FFS patient.

Assuming the above is considered and satisfied, bonus points are awarded as follows:

- Each additional outcome or patient experience measure = 2 bonus points.
- Each additional high priority measure = 1 bonus point.

Note that if you don’t report six measures, you can still earn bonus points, but only if you’re doing so because of lacking availability of applicable measures. Otherwise, you can earn bonus points on as many high priority measures as you report - both including the initial six, and including any additional measures you report. So, be sure your measure selection strategy includes as many outcomes and high priority measures as possible!

Bonus Points Earned by Reporting Via End to End Reporting

The second way to earn bonus points in the Quality category is to report your measures via end to end electronic reporting. But, again, earning these bonus points has some nuances to keep in mind:

1) The amount of bonus points available is capped at 10% of the total points available to the reporter in the quality category. So, this isn’t a huge bonus either. But, note that each bonus point category is a separate cap, so you can max out both separately.
2) Bonus points can be earned only if reporting via qualified registries, QCDRs, EHRs, or the CMS Web Interface, and when end to end electronic reporting is utilized. Claims reporters won’t qualify for these bonus points.

Keeping these considerations in mind, each measure reported via end to end electronic reporting will receive 1 bonus point.

Once all of that is determined, both types of bonus points are added to the score from the initial measures, and then divided by the total points available to that reporter in the quality category. This number is then multiplied by 60, which is the weight of the quality category in the final score. This is your final score for the Quality category.

 

Image: 2017 MIPS Quality Performance Category Fact Sheet


Yahoo! That’s Everything for Quality!

We made it through Quality scoring! Noice! One last note before we go -  all the information above is most relevant to 2017 performance year registry reporting, and there are some quirks depending on which type of submission mechanism you choose. pMD is a qualified registry, so we focused on that aspect of MIPS Quality scoring. If you have any questions or would like to learn more about our MIPS registry, give us a call! And, of course, to find out more about pMD's suite of products, which includes charge capture, secure messaging, and care coordination software and services, please contact pMD.

References:

Each reported quality measure will receive between 3 and 10 points: “[W]e will provide points for all submitted measures, but only a subset of measures receives points based on performance against a benchmark.” See https://www.federalregister.gov/d/2016-25240/p-3502; see also Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502 (illustrating that there are two categories for submitted quality measures one category that recieves 3 points and one category that receives between 3 and 10 points).

To receive more than 3 points, the reported quality measure must have a benchmark, have 20 cases, and meet the data completeness standard: See Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502.

When reporting through QCDRs, qualified registries, and EHRs, data completeness means reporting on 50% of all-payer data for that measure, and including at least one Medicare patient: Data completeness will include “all-payer data for the QCDR, qualified registry, and EHR submission mechanisms... In addition, those clinicians who utilize a QCDR, qualified registry, or EHR submission must contain a minimum of one quality measure for at least one Medicare patient.” See https://www.federalregister.gov/d/2016-25240/p-1492.

If any of the reported quality measures are missing the minimum requirements, they will receive 3 points: See Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.

Comparing reported quality data against the national benchmark determines if a measure will receive more than 3 points: “When a clinician submits measures for the MIPS Quality Performance Category, each measure is assessed against its benchmarks to determine how many points the measure earns.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.  

National benchmark data used for the MIPS 2017 performance year is taken from 2015 PQRS performance data: “These historic benchmarks are based on actual performance data submitted to PQRS in 2015, except for CAHPS.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”

Each benchmark is broken into deciles: “Each benchmark is presented in terms of deciles.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.

There is a different benchmark for each submission mechanism: “Benchmarks are specific to the type of submission mechanism: EHRs, QCDRs/Registries, CAHPS and claims.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”

To maximize your MIPS score, you should fully report at least 6 measures: “[F]or any MIPS eligible clinician who does not report a measure required to satisfy the quality performance category submission criteria, we proposed that the MIPS eligible clinician would receive zero points for that measure. For example, a MIPS eligible clinician who is able to report on six measures, yet reports on four measures, would receive two “zero” scores for the missing measures.” See https://www.federalregister.gov/d/2016-25240/p-3513.

If you choose to report more than 6 quality measures, then the measures with the highest points assigned with be used: “If a MIPS eligible clinician elects to report more than the minimum number of measures to meet the MIPS quality performance category criteria, then we will only include the scores for the measures with the highest number of assigned points, once the first outcome measure is scored, or if an outcome measure is not available, once another high priority measure is scored.” See https://www.federalregister.gov/d/2016-25240/p-3623.

All measure results submitted will become public information: “[W]e are finalizing our proposal to report on Physician Compare the final score for each MIPS eligible clinician, performance of each MIPS eligible clinician for each performance category, and to periodically post aggregate information of such data. Accordingly, we are finalizing § 414.1395(a), which provides that for public reporting of an eligible clinician's MIPS data in that for each program year, we will post on a public Web site, in an easily understandable format, information regarding the performance of MIPS eligible clinicians or groups under the MIPS.” See https://www.federalregister.gov/d/2016-25240/p-4762. See also 81 FR 77394, available at https://www.federalregister.gov/d/2016-25240/p-4767. (“[W]e proposed to make all measures under the MIPS quality performance category (81 FR 28184) available for public reporting on Physician Compare (81 FR 28291). This would include all available measures reported via all available submission methods, and applies to both MIPS eligible clinicians and groups.” Proposed policy finalized at 81 FR 77395, available at https://www.federalregister.gov/d/2016-25240/p-4781).

If you report less than 6 measures, you’ll be scored on whatever is submitted, and receive zero points for any measure that could have been reported but was not: “Previously in PQRS, EPs had to meet all the criteria or be subject to a negative payment adjustment. However, we proposed that MIPS eligible clinicians receive credit for measures that they report, regardless of whether or not the MIPS eligible clinician meets the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3513; “After consideration of the comments, we are finalizing at § 414.1380(b)(1)(vi) that MIPS eligible clinicians who fail to report a measure that is required to satisfy the quality performance category submission criteria will receive zero points for that measure.” See also https://www.federalregister.gov/d/2016-25240/p-3524.  

You can receive bonus points in the quality category, but these bonus points are capped at 10%: [W]e are increasing the cap for high priority measures from 5 percent to 10 percent of the denominator (total possible points the MIPS eligible clinician could receive in the quality performance category)  of the quality performance category for the first 2 years.” See https://www.federalregister.gov/d/2016-25240/p-3561/.

To receive bonus points, the reporter must submit at least one scored high priority measure: “The MIPS eligible clinician can receive bonus points on all high priority measures submitted, after the first required high priority measure submitted, assuming these measures meet the minimum case size and data completeness requirements...” See https://www.federalregister.gov/d/2016-25240/p-3550; see also 81 FR 77292 https://www.federalregister.gov/d/2016-25240/p-3529 (“We noted that a MIPS eligible clinician who submits a high priority measure but had a performance rate of 0 percent would not receive any bonus points. MIPS eligible clinicians would only receive bonus points if the performance rate is greater than zero.”)

If you do not submit 6 measures, due to lacking availability of measures, you can still receive bonus points: “The MIPS eligible clinician can receive bonus points on all high priority measures submitted, after the first required high priority measure submitted, assuming these measures meet the minimum case size and data completeness requirements even if the MIPS eligible clinician did not report all 6 required measures due to lack of available measures.” See https://www.federalregister.gov/d/2016-25240/p-3550.

Measures that receive bonus points must be reported with at least 20 instances, and meet the data completeness standard, which for registries is 50% of all encounters reported, with 1 Medicare Part B FFS patient included:  “Bonus points are also available for measures that are not scored (not included in the top 6 measures for the quality performance category score) as long as the measure has the required case minimum and data completeness.” See https://www.federalregister.gov/d/2016-25240/p-3529.

Bonus points will be awarded on all reported measures that hit the 20 case minimum and the data completeness standard - both including the original 6 reported and any additional measures reported: “Bonus points are also available for measures that are not scored (not included in the top 6 measures for the quality performance category score) as long as the measure has the required case minimum and data completeness.” See https://www.federalregister.gov/d/2016-25240/p-3529.

Each outcome or patient experience measure reported in addition to the required high priority measure will receive 2 bonus points: “[W]e are finalizing at § 414.1380(b)(1)(xiii) our proposal to award 2 bonus points for each outcome or patient experience measure ... that is reported in addition to the 1 high priority measure that is already required to be reported under the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3553.

Each high priority measure reported in addition to the required high priority measure will receive 1 bonus point: “[W]e are finalizing at § 414.1380(b)(1)(xiii) our proposal to award ... 1 bonus point for each other high priority measure that is reported in addition to the 1 high priority measure that is already required to be reported under the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3553.

The cap for bonus points earned via end to end electronic reporting is 10%: “[W]e are increasing the cap for using CEHRT for end-to-end reporting from 5 percent to 10 percent of the denominator of the quality performance category (total possible points for the quality performance category) for the first 2 years.” See https://www.federalregister.gov/d/2016-25240/p-3598.

The cap for end to end electronic reporting is distinct from the cap for reporting additional high priority measures: “MIPS eligible clinicians will be eligible for both the CEHRT bonus option and the high priority bonus option with separate bonus caps for each option.” See https://www.federalregister.gov/d/2016-25240/p-3598.

You can only earn the end to end electronic reporting bonus if reporting via qualified registries, QCDRs, EHRs, or the CMS Web Interface, and end to end electronic reporting is utilized: “We are finalizing that the CEHRT bonus would be available to all submission mechanisms except claims submissions. Specifically, MIPS eligible clinicians who report via qualified registries, QCDRs, EHR submission mechanisms, and CMS Web Interface in a manner that meets the end-to-end reporting requirements may receive one bonus point for each reported measure with a cap as described.” See https://www.federalregister.gov/d/2016-25240/p-3599.  

Each measure reported via end to end electronic reporting will receive 1 bonus point: 77298 “After consideration of the comments, we are finalizing at § 414.1380(b)(1)(xiv) one bonus point is available for each measure submitted with end-to-end electronic reporting for a quality measure under certain criteria described in this section.” See https://www.federalregister.gov/d/2016-25240/p-3598.  

To calculate the quality category final score, bonus points are added to the score of the initial measures, divided by the total possible points, and then that number is multiplied by 60: “We will sum the points assigned for the measures required by the quality performance category criteria plus the bonus points and divide by the weighted sum of total possible points. The quality performance category score cannot exceed the total possible points for the quality performance category.” See https://www.federalregister.gov/d/2016-25240/p-3623; see also 81 FR 77276-7, available at https://www.federalregister.gov/d/2016-25240/p-3375.; see also 81 FR 7300-1, available at https://www.federalregister.gov/d/2016-25240/p-3631 (examples of scoring calculation).

The weighting for the Quality category is 60%: “Therefore, we are finalizing at § 414.1330(b) for MIPS payment years 2019... 60 percent … of the MIPS final score will be based on performance on the quality performance category.” See https://www.federalregister.gov/d/2016-25240/p-1164.