Even though we are in the final stages of putting closure to the 2019 MIPS Performance Year, we do want to make sure you have your 2020 Performance Year plan in place. If you wait, you will be late. The Merit-based Incentive Payment System (MIPS) is now going on the 4th year. 45 points is the new minimum MIPS Composite Score required to avoid a 9% penalty (instead of 30 points for 2019). There are even more financial risks and rewards at stake. The MIPS reporting strategies will need to involve ways to maximize your scores in all three of the categories that are in your direct control – Quality, Promoting Interoperability and Improvement Activities.
Here are some tips to help you select a Qualified Registry that offers the best opportunity for your organization to minimize MIPS reporting burden while maximizing the MIPS scores:
1. Leverage Multiple Collection Types
From the 2019 Performance Year onward, CMS has allowed Eligible Clinicians (ECs) the flexibility to report Quality Measures through multiple submission methods. vs. having to choose just one submission method. There are three main Collection Types available to eligible clinicians for submission of Quality Measures.
eCQMs- Submission by an EHR (and some Registries)
MIPS CQMs – Registry Submission
Claims – Sent direct to CMS
EHRs can only handle submission of eCQMs and the eCQMs must be certified by the EHR. In 2020 there are a maximum of 47 eCQMs available, with the average EHR certifying between 9 to 12 measures. There are 196 MIPS CQMs available to Qualified Registries. Claims measures will be handled by adding the appropriate g-codes and or modifiers to the claims prior to submitting the claims to CMS. Note: A claim cannot be resubmitted if the reason is just to add the Quality Measure g-codes.
2. Utilize a Qualified Registry if Submitting a Mix of EHR and Registry Measures
Signing up with a CMS-approved Qualified Registry (QR) can be your submission method of choice that will allow you to take care of all your MIPS reporting requirements. A QR (like MyMipsScore) supports reporting all the combined 243 Quality Measures (eCQMs and MIPS CQMs) offering you the best of both worlds. Additionally, if your EHR does not have a certain Quality Measure available as an eCQM, the QR could provide an alternative opportunity to report measures as a MIPS CQM. However, there is one caveat. While selecting a Qualified Registry, please make sure that the registry your organization has selected does support end-to-end reporting of MIPS-CQMs.
Note: The CEHRT bonus makes up to 10% of your Quality Category Score.
3. Look for a Qualified Registry that Supports Reporting of PI, IA, and Quality
A QR that supports reporting of all the Improvement Activities and the Promoting Interoperability measures in addition to all the Quality measures will provide you with the maximum flexibility on reporting all three categories and to be able to customize your reporting to fit your scope-of-practice and patient mix.
4. Analytical Capabilities for Multi-Specialty and Multi-Location Practices
The ability to run multiple scenarios throughout the year to determine the best combination of Quality Measures (eCQM’s and MIPS) will prove very valuable. It will help your organization find the measures that work best for the provider-mix for multi-specialty and multi-location practices.
5. MIPS Partner Who Provides Complete a MIPS Solution
Look for a QR that works as your MIPS partner and will do the heavy lifting regarding the pre-submission conformance to all the CMS requirements for each category (Data Completeness, Case Minimums, Small Practice considerations and the allowable exclusions and or exceptions). Adhering to these requirements can make a significant difference in the score that each category measure receives. A measure with a high-performance rate could receive only 3 points for a small practice (<15 providers), or 0 points for a large group (>15 providers) if the Case Minimums and or the Data Completeness have not been achieved.
Next Steps
The time is right to implement your MIPS reporting strategy for 2020. The Quality category continues to account for the largest portion of your total MIPS score, so focusing on a reporting strategy that maximizes your Quality points is very important. CMS permits ECs to report measures through multiple reporting methods, so it is worth considering to report via a Qualified Registry to improve your reporting performance rates and scores. The team at MyMipsScore is available to provide guidance right from eligibility till the submission of data to ensure you have the support, tools and all the information that you need to succeed in MIPS.
