MIPS Extreme & Uncontrollable Circumstances Application Extended
Hope McCain March 5th, 2021 Categories: featured, MIPS Information
Tags: CMS, covid-19, MIPS, Performance Year, QPPMIPS 2021: Proposed Rule Key Takeaways
The Centers for Medicare and Medicaid Services (CMS) has released the Quality Payment Program (QPP) proposed rule for the 2021 performance year. To accommodate for the challenges posed by COVID-19, CMS is not proposing many significant changes to the Merit-based Incentive Payment System (MIPS) for 2021. Here are the highlights of the proposed rule for next year. For information on the current performance year, see our MIPS 2020 page.
MIPS Value Pathways
Introduction of MIPS Value Pathways (MVPs), the new framework originally set to begin implementation in the 2021 performance year, will be postponed. CMS will continue to work on engaging stakeholders and developing the framework’s guiding principles.
APM Performance Pathway
CMS has proposed an APM Performance Pathway (APP), complementary to MVPs. This option would be available to MIPS APM participants only and would be composed of a fixed set of measures for each performance category. The APP performance measures would also satisfy reporting requirements for the Medicare Shared Savings Program quality scoring.
Performance Category Weights
In 2021, the proposed Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.
Performance Threshold
For the 2021 performance period, CMS proposes to increase the performance threshold (maximum number of points needed to avoid a negative payment adjustment) from 45 to 50 points. There is no change to the exceptional performance threshold (number of points needed for a positive payment adjustment) of 85 points.
Performance Categories
Quality Category
CMS proposes to use performance period benchmarks, rather than historical, to score quality measures. Previously, the benchmarking baseline period was the 12-month calendar year two years prior to the MIPS performance year. CMS hopes to ensure accurate and reliable data due to possible gaps in baseline data due to COVID-19. Therefore, in 2021, the agency proposes to use benchmarks from the 2021 performance period instead of the 2019 calendar year.
CMS also proposes to end the CMS Web Interface as a quality reporting option for ACOs and registered groups, virtual groups, or other APM Entities beginning with the 2021 performance period.
Improvement Activities Category
Minimal updates would be made to the Improvement Activities inventory. A process would also be established for agency-nominated improvement activities.
In 2021, there are no proposed changes to the requirement that at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.
Cost Category
CMS proposes to update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the TPCC measure.
COVID-19 Flexibility Scoring Proposals
For the 2020 performance period only, the maximum number of bonus points available for the complex patient bonus would be 10, to account for the additional complexity of treating patients during the COVID-19 public health emergency.
You can view the full 2021 QPP Proposed Rule fact sheet here.
MIPS and SurveyVitals
SurveyVitals can help you satisfy certain MIPS requirements. Learn more on our MIPS page, sign up for a demo, or chat with us using the blue chat icon below.
blake August 6th, 2020 Categories: featured, MIPS Information
Tags: CMS, covid-19, Improvement, improvement activities, macra, MIPS, QCDR, QPP, Quality, quality category, quality payment programMIPS 2021: MVPs and QCDR Changes Coming
Last week, CMS released the final rule for the changes to the Merit-Based Incentive Payment System (MIPS). While there are only minor changes to the program in 2020, bigger changes are expected in 2021. Here are two of the big takeaways from the final rule.
MIPS Value Pathways (MVPs)CMS intends to move toward what they say would be a more streamlined MIPS program. To fulfill upon this vision, the agency intends to reduce reported complexities with data submission and confusion surrounding measure selection with a new framework they are calling MIPS Value Pathways (MVPs).
In the MVP framework, CMS intends to work with stakeholders to create sets of measure options that they say would be more relevant to clinician scope of practice and meaningful to patient care. MIPS-eligible clinicians would no longer choose their measures from a single inventory, but would instead fulfill pre-defined measures and activities connected to a specialty or condition.
At this time, CMS has not determined whether participation in MVPs in 2021 would be optional or mandatory.
Many aspects of the MVP framework are still unclear, and we will be following and providing updates as they are released by CMS. Subscribe to our MIPS newsletter to keep up to date on the MVP discussion.
Qualified Clinical Data Registries (QCDR)In the current QPP landscape, QCDRs are not required to support multiple MIPS performance categories. However, beginning in performance year 2021, QCDRs will be required to submit data for the Quality, Improvement Activities, and Promoting Interoperability categories for the entire performance year and applicable submission period.
CMS is looking to achieve alignment of similar measures across QCDRs, with an emphasis on outcome measures. Starting in 2021, this would require full measure development and testing at the clinician level prior to the time of self-nomination. Additionally, CMS would implement a set of formalized guidelines for QCDR measure rejections.
You can read more about these proposed changes in the Quality Payment Program final rule.
blake November 6th, 2019 Categories: featured, MIPS Information
Tags: CMS, Improvement, improvement activities, macra, MIPS, QCDR, QPP, Quality, quality category, quality payment programMIPS 2020: Key Takeaways
Last week, CMS released the final rule for the changes to the Merit-Based Incentive Payment System (MIPS) in 2020. Changes to the program next year are minimal, but are still important to note as you head into performance year 4.
Performance Category WeightsThere will be no change to the performance category weights in MIPS performance year 2020.
For the 2020 performance period, the performance threshold (maximum number of points needed to avoid a negative payment adjustment) will increase from 30 to 45 points. The additional performance threshold for exceptional performance will increase from 75 points to 85.
The maximum positive payment adjustment for performance year 2020 will be increased to 9%, plus additional adjustments for exceptional performance. The maximum negative payment adjustment will be -9%.
Quality Performance CategoryData completeness for performance year 2020 will increase from 60% to 70%. This means you must report on at least 70% of your total patients who meet the measure’s denominator criteria in order to receive maximum points for the measure.
Improvement Activities CategoryThe Improvement Activities inventory has been updated for MIPS performance year 2020.
| MIPS Year 4 Changes to Improvement Activities | |
|---|---|
| Added |
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| Modified |
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| Removed |
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Previously, a group or virtual group could attest to an improvement activity if at least one clinician in the group participated in the activity. In 2020, in order for a group or virtual group to attest to an improvement activity, at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.
CMS has also made a technical correction to the definition of ‘Rural Area’ that will not change how rural clinicians are identified.
Also modified are the requirements for patient-centered medical home (PCMH) designation. CMS has removed specific examples of entity names of accreditation organizations in order to remove barriers to designation.
Promoting InteroperabilityCurrently, hospital-based clinicians who choose to report as a group or virtual group are eligible for reweighting when 100% of the MIPS-eligible clinicians in the group meet the definition of a hospital-based MIPS eligible clinician. In the next performance year, these clinicians are eligible for reweighting when more than 75% of the NPIs in the group or virtual group meet the definition of a hospital-based MIPS eligible clinician.
MIPS Performance Year 2021Although there are no major changes to the program for 2020, bigger changes are expected in performance year 2021. Subscribe to our MIPS newsletter to stay up to date on these future changes.
blake November 5th, 2019 Categories: featured, MIPS Information
Tags: CMS, improvement activities, macra, MIPS, QCDR, Quality, quality category, quality payment programCMS Proposes New Measure Specialty Sets, MIPS Value Pathways
The final rule for MIPS 2020 outlines the changes to the MIPS program coming in 2021. Read more here.
This week, CMS released the proposed rule for Year 4 of the Quality Payment Program (QPP). Many of the Year 3 requirements will be maintained going into the 2020 performance year; we highlighted the proposed changes in our blog post here. However, there are bigger proposed changes in store for Year 5 of the QPP starting in 2021.
In the latest release, CMS expressed an intention to move toward what they say would be a more streamlined MIPS program. To fulfill upon this vision, the agency is aiming to reduce reported complexities with data submission and confusion surrounding measure selection with a new framework they are calling MIPS Value Pathways (MVPs).
Check out key takeaways below from the proposed rule on MVPs and what CMS has put forth as a very loose framework for the future of the program.
CMS is soliciting public comment on the proposed rule until September 27, 2019 at 5 PM EST.
MIPS Value Pathways defined
The MVP framework would create sets of measure options that CMS says would be more relevant to clinician scope of practice and meaningful to patient care by connecting MIPS measures across the four performance categories specific to specialty or condition. It would also incorporate a set of administrative claims-based quality measures that focus on population health and provide data and feedback to clinicians. CMS says it intends to use the current MIPS specialty measure sets as a base framework for developing these new MVPs. The agency also indicated they will seek to enhance information provided to patients, with possible exploration of new forms of public reporting.
How does the MVP framework change MIPS?
If implemented, all MIPS-eligible clinicians would no longer choose their measures from a single inventory, but would instead fulfill measures and activities connected to a specialty or condition as a part of an MVP. This means the MIPS program would no longer require the same number of measures or activities for all clinicians.
CMS anticipates that an MVP would use a single benchmark for each measure, and all clinicians and groups in the MVP would be compared against the same standard. It is proposed that scoring policies would be evaluated to ensure scoring across MVPs is equitable, so that clinicians reporting a specific MVP are not unfairly advantaged. The agency says this would eliminate the need for special scoring policies and bonuses to incent selection of high priority or outcome measures, as clinicians would be required to report all measures in the MVP.
Additionally, MVPs will focus on bundling quality measures with existing, related cost measures and improvement activities as CMS sees feasible.
How will MIPS data collection be impacted by MVPs?
It is unclear at this time exactly how clinicians and groups will be expected to report data to satisfy measures under the new MVP framework. CMS says that the current MIPS performance measure collection types will continue to be used to the “extent possible,” creating some uneasiness for clinicians and industry leaders who have invested time and resources in their current reporting mechanisms. CMS is soliciting feedback around data submission mechanisms, particularly QCDRs and their role in the program. The agency maintains that a driving force behind the proposed changes is that the flexibility of the program in years 1-3 resulted in multiple benchmarks for each measure and specialty, hindering the ability of CMS to make meaningful comparisons.
Agency emphasizes patient experience and patient reported outcomes
The proposed rule also emphasized an increased focus on patient reported measures, including patient experience, satisfaction and outcomes in their performance measurement. The agency anticipates the MVP framework will provide more meaningful information to patients, which will enable them to make decisions about their care and achieve better outcomes.
| CMS Example of Possible MIPS Value Pathway | ||||
|---|---|---|---|---|
| MVP Example | Quality Measures | Cost Measures | Improvement Activities | Promoting Ineroperability |
| Preventive Health |
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blake August 1st, 2019 Categories: featured, MIPS Information, Patient Experience
Tags: CMS, improvement activities, macra, MIPS, QCDR, QPP, Quality, quality category, quality payment programDo Not Miss This MIPS Reporting Deadline
View up-to-date information on our MIPS resource page here!
Avoiding A MIPS Negative Payment Adjustment
October 2nd marks the very last day for eligible clinicians to start collecting MIPS data for partial year submission. If this fall reporting deadline is missed, clinicians and/or groups will not be eligible to receive a positive payment adjustment in 2019. Rather, they will be faced with two outcomes:
- Submit the minimum amount of data and receive a neutral payment adjustment
- Submit no data and receive a downward payment adjustment (up to -4%)
Given the flexibility of the MIPS program this year, it would be a missed opportunity for groups and clinicians to submit just 90-days of performance data to Medicare to earn a moderate positive payment adjustment – maybe even the max adjustment – in 2019. Learn more about MIPS and “Pick Your Pace” here.
While it might seem a bit daunting if you haven’t started, there is still a short window of time for you and/or your group to select the required number of measures and get up and running before the partial submission deadline passes.
Partial Submission Pace
In order to participate in the ‘partial submission’ pace as outlined by the Centers for Medicare and Medicaid Services, eligible clinicians and groups will need to submit 90 consecutive days worth of performance data to Medicare across the following MIPS scoring categories:
- Quality Category: 6 Measures
- Advancing Care Information: 9 measures
- Improvement Activities: a combination of measures totaling 40 points
For clinicians in rural or health professional shortage areas, or for those clinicians considered non-patient facing or “hospital-based,” you may face reduced reporting requirements. Learn more about these special status groups under MIPS here.
Selecting A Submission Mechanism and Measures
Submission methods may vary based on the measure.
Meeting Measures with SurveyVitals
Finally, SurveyVitals can help you meet a number of measures in the Improvement Activities category, including a high-weight activity. Additionally, SurveyVitals can submit data to your QCDR and help you administer CAHPS for MIPS. Want to learn more about meeting MIPS measures with SurveyVitals? Contact us at info@surveyvitals.com
blake September 15th, 2017 Categories: Anesthesia, featured, MIPS Information, Outpatient Practice
Tags: CMS, macra, MIPS, QPP, reporting deadlineIs GPRO the way to go?
Update: GPRO is a part of the retired PQRS program that has been replaced by MIPS under the Quality Payment Program (QPP). Learn more about MIPS here.
At SurveyVitals, we believe there’s great value in the Qualified Clinical Data Registry (QCDR) quality data reporting option. In 2015, only Eligible Professionals (EPs) can report through a QCDR. Some great news is that CMS recently shared they’re adding a reporting option allowing group practices to report quality measure data using a QCDR for 2016. Please read below for more detail about the differences between GPRO and QCDR.
By now, everyone understands that physicians who don’t report adequate quality measures in 2015 will see a 2% penalty in 2017. There are still questions, however, about the best way to report your quality data to CMS, especially for outpatient practices. And while the date to adjust your 2015 reporting mechanism has passed, we’d like to share some information as you start thinking about your plan for 2016.
At the highest level, you must decide whether to report as an individual EP (Eligible Professionals) or as part of a group. There are pros and cons to each, although SurveyVitals® recommends the individual EP route. Among other reasons, this option allows you to submit quality data through a QCDR (Qualified Clinical Data Registry) if one exists for your specialty.
GPRO, the Group Practice Reporting Option, is another method to submit your quality data, but has numerous CMS requirements. Here are a few things we’d like our clients to know about GPRO for 2015:
- GPRO is optional.
- GPRO only applies to EPs with a common Tax Identification Number (TIN).
- If you chose a GPRO reporting method, the decision is irreversible for 2015 (the deadline was June 30, 2015).
- You cannot submit your data through a QCDR if you choose GPRO.*
- If you choose GPRO and have 100 or more EPs (25 or more for 2016), you’ll be required to run the CAHPS for PQRS survey. The survey is optional in 2015 for groups of 2-99 EPs.
- Most importantly, the survey is tailored to primary care.
- The survey will not be paid for or administered by CMS. Participating groups will be required to contract with a CMS-certified vendor to administer the CAHPS for PQRS survey.
- The CAHPS for PQRS survey will be administered on paper with live phone follow-ups for non-responders. Surveys sent via email or text message aren’t allowed at this time, which makes improvement based on real-time feedback virtually impossible. This is why SurveyVitals is not a CMS-certified vendor.
- CAHPS for PQRS does count as a measure.
Choosing whether to report quality measures as a group or by individual can be a complicated decision when you factor in eligibility and reporting requirements, and here’s why we recommend individual reporting:
- Individual EPs can submit through QCDRs:
- QCDRs can focus on more relevant, specialty-specific quality measures. Now is the time to promote the QCDR concept and its benefits to your specialty board.
- The QCDR collects data for the purpose of providing improved quality of care for patients.
- There is greater potential to meet the reporting requirement of 9 measures across 3 National Quality Strategy domains.
- The QCDR typically submits data to CMS on your behalf.
As we announced earlier this year, our Patient Satisfaction Questionnaires (APSQ, SPSQ, or HSQ), fulfills measures for many QCDRs. We’re working to get a patient satisfaction measure included in other QCDRs for 2016. We expect that the list will continue to grow, so contact us if you’d like additional information on the measures SurveyVitals can help you meet for each QCDR.
If you don’t report through a QCDR, it is still beneficial to report individually since the measures that must be reported to CMS are the same. Although some variations exist in the methods (for 2015, claims-based for individual reporting and web interface for GPRO 25+ EPs), you can avoid the CAHPS for PQRS survey requirement and its expense. Additionally, the Value-Based Payment Modifier (VM) is not affected by reporting individually since the VM is calculated by TIN.
* In late October 2015, CMS released some preliminary information regarding PQRS for 2016. From the CMS website: “CMS makes changes to the PQRS measure set to add measures where gaps exist, as well as to eliminate measures that are topped out, duplicative, or are being replaced with a more robust measure. There will be 281 measures in the PQRS measure set and 18 measures in the GPRO Web Interface for 2016. Also, as recently authorized under MACRA, CMS is adding a reporting option that will allow group practices to report quality measure data using a Qualified Clinical Data Registry (QCDR).
We’ll wait for the final 2016 PQRS webpage to become available (typically by January 1, 2016) to see how this plays out, and SurveyVitals will attempt to stay on top of these ever changing requirements in order to provide the most value to our clients. Stay tuned for more!
blake November 13th, 2015 Categories: CAHPS Surveys, featured, MIPS Information
Tags: CMS, GPRO, PQRS, QCDRTo GPRO, or not to GPRO, that is the question for anesthesiology providers
By now, everyone understands that physicians who don’t report adequate quality measures in 2015 will see a 2% penalty in 2017. There are still questions, however, about the best way to report your quality data to CMS, especially for anesthesiology providers. And while the date to adjust your 2015 reporting mechanism has passed, we’d like to share some information as you start thinking about your plan for 2016.
At the highest level, you must decide whether to report as an individual EP (Eligible Provider) or as part of a group. There are pros and cons to each, although SurveyVitals® recommends the individual EP route. Among other reasons, this option allows you to submit quality data through a QCDR (Qualified Clinical Data Registry).
GPRO, the Group Practice Reporting Option, is another method to submit your quality data, but has numerous CMS requirements. Here are a few things we’d like our clients to know about GPRO:
- GPRO is optional.
- GPRO only applies to EPs with a common Tax Identification Number (TIN).
- If you chose a GPRO reporting method, the decision is irreversible for 2015 (the deadline was June 30, 2015).
- You cannot submit your data through a QCDR if you choose GPRO.
- If you choose GPRO and have 100 or more EPs (25 or more for 2016), you’ll be required to run the CAHPS for PQRS survey. The survey is optional in 2015 for groups of 2-99 EPs.
- The survey is tailored to primary care, which does not help anesthesiology providers.
- The survey will not be paid for or administered by CMS. Participating groups will be required to contract with a CMS-certified vendor to administer the CAHPS for PQRS survey.
- The CAHPS for PQRS survey will be administered on paper with live phone follow-ups for non-responders. Surveys sent via email or text message aren’t allowed at this time, which makes improvement based on real-time feedback virtually impossible. This is why SurveyVitals is not a CMS-certified vendor.
- By reporting via GPRO, you’re agreeing to have your PQRS performance results publicly posted on the Physician Compare website. The performance rates will apply to the entire group.
Choosing whether to report quality measures as a group or by individual can be a complicated decision when you factor in eligibility and reporting requirements, and here’s why we recommend individual reporting:
- Individual EPs can submit through QCDRs:
- QCDRs can focus on more relevant, anesthesia-specific quality measures.
- The QCDR collects data for the purpose of providing improved quality of care for patients.
- There is greater potential to meet the reporting requirement of 9 measures across 3 National Quality Strategy domains.
- The QCDR typically submits data to CMS on your behalf.
- As the ASA said on its website, “Participation in [the] ASA QCDR not only helps protect a practice’s income, but it also helps keep money in the practice so you can continue your focus on patient safety.
As we announced earlier this year, our Anesthesia Patient Satisfaction Questionnaire, the APSQ, fulfills measure #16 for NACOR, the Composite Patient Experience, and counts as an outcome measure as well. We’re also working to get a patient satisfaction measure included in other QCDRs like ABG and ASPIRE for 2016. We expect that list will continue to grow, so contact us if you’d like additional information on the measures SurveyVitals can help you meet for each QCDR.
If you don’t report through a QCDR, it is still beneficial to report individually since the measures that must be reported to CMS are the same. Although some variations exist in the methods (for 2015, claims-based for individual reporting and web interface for GPRO 25+ EPs), you can avoid the CAHPS for PQRS survey requirement and its expense. Additionally, the Value-Based Payment Modifier (VM) is not affected by reporting individually since the VM is calculated by TIN.
SurveyVitals will attempt to stay on top of these ever changing requirements in order to provide the most value to our clients. Stay tuned for more!
blake October 7th, 2015 Categories: Anesthesia, CAHPS Surveys, featured, MIPS Information
Tags: CMS, GPRO, NACOR, Oct 2015, PQRS, QCDRRecent Posts
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