COVID-19 has impacted all aspects of healthcare including the MIPS program. To that end, CMS did extend some relief to clinicians participating in MIPS for 2019. After the public health emergency was declared in March 2020, we have received many inquiries from provider organizations about relaxations for MIPS 2020 performance year. CMS is taking action regarding MIPS 2020 by offering COVID-19 related relaxation and adjustment. These announcements are trickling in slowly and might not be what you anticipated. The latest update was released on Jun 24, 2020. There might be additional tweaks and retroactive adjustments that are announced later in the year, but reading between the lines, it is evident that MIPS will go on.
We witnessed up close how different provider organizations handled MIPS 2019 submissions during COVID-19 pandemic ranging from single providers to multi-specialty and multi-location practices. Some organizations handled the crisis better than the others. In this blog we have distilled the lessons learned from these provider organizations into 10 things they did right.
Relief for MIPS 2020 Clinicians by CMS as of Today
Before venturing into the lessons, let’s first summarize MIPS 2020 flexibilities due to COVID-19 that CMS has announced for the clinicians participating in the MIPS track of the QPP program so far.
Jun 24, 2020: Extreme & Uncontrollable Circumstances Application for clinicians significantly impacted by COVID-19
Clinicians or groups significantly impacted by COVID-19 may submit an Extreme & Uncontrollable Circumstances Application to reweight one or all the MIPS performance categories. However, the request to reweight any of the category (Quality, PI, IA, Cost) must be supported by adequate justification on how their practice has been significantly impacted by the public health emergency.
April 2020: New COVID-19 Clinical Trials Improvement Activity Added
MIPS eligible clinicians or groups can receive credit for this new Improvement Activity by:
Participating in a COVID-19 clinical trial and have the data entered into the designated data platform for that study; or
Submitting clinical COVID-19 patient data of the COVID-19 patients they cared for to a clinical data registry for purposes of future study
Now let’s dive into the lessons.
1. Check Eligibility Status
Every MIPS performance year has two determination periods. To be eligible for a MIPS performance year, you need to be eligible in both the determination periods. Every year, you need to check for your organization:
MIPS Eligibility for 2020 as an Individual and or a Group
Providers who are a part of multiple TINs will need to submit data for all practices that they are MIPS eligible. If not careful, ECs could receive an incentive with one practice and be penalized for failure to report with another.
APM members can have Quality and IA covered by the organization
You do not need to declare to CMS how the providers in your group intend to submit their data as Group or as Individuals before the actual data submission. You can analyze your data throughout the year with apps like MyMipsScore for Group vs. Individual Submission and then make your submission decision based on the data.
2. Determine Incentive Potential
Determine your Group’s combined Medicare Part B reimbursement to see the incentive potential for electing to opt in as a Group. You might be able to boost your potential positive payment adjustment significantly by paying attention to the measures you are reporting and how you are reporting them. You can determine your incentive potential for 2020 using the MIPS Calculator.
3. Stay on Course for MIPS 2020
If you won’t be claiming the “Extreme and Uncontrollable Circumstances Exception” for 2020, do not wait until the end of the year to address your MIPS requirements. I say this based on our experience and observations while working with multiple specialties and practices both large and small. Keep in mind that the 2019 MIPS Performance Year was completed prior to the COVID-19 crisis. A vast majority of ECs did wait until the end of the year to focus on their MIPS reporting. This led to 11th hour scramble for data and consumed a lot of staff hours looking back into patient records. Additionally, the data accuracy suffered and the potential for higher scores was lost.
Quality Reporting is still for the full year, as of now.
IA and PI still require reporting data for the best 90 continuous days. The last quarter may not be the best for your organization, whether you are reporting as a Group or as Individuals.
The real solution is to visit your MIPS plan and analyze your data at least once a quarter. This will allow you to get a feel for your progress and to trend out the plan throughout the year. This will also allow for any corrective action that might be needed on data collection.
4. Pay Special Attention to Promoting Interoperability (PI) Category
PI is an all or nothing category. This means you need to address every measure. You can take the measure exclusion(s) if they apply, however, you must address each measure.
When you claim exclusion for a PI measure, the points for that measure will be reweighted to another measure under the same objective, or to another objective completely. For instance:
Claiming exclusion for the “Send” portion of Health Information Exchange, reweights the points to the “Receive” portion of the Health Information Exchange
Claiming exclusion for both Send and Receive Health Information Exchange reweights points for both the measures to Provider to Patient Exchange measure.
The Security Risk Analysis portion within the PI category can be completed anytime during the 2020 Performance Year. It does not need to be completed in the same reporting period as the other PI measures. It is a must-do activity, or you will not receive a PI score.
5. Check the Clinical Quality Measure (CQM) Benchmarks
Each year CMS relooks at every measure and assigns it the new decile performance rates based on the past performance data reported.
The 50% performance rate in 2019 that scored an 8 might now only be able to receive a 4 due to a reassigned benchmark.
If a measure is available via multiple collection types (Claims, eCQM, MIPS-CQM), a different benchmark is applicable for each collection type which changes every year.
Additionally, some measures become Topped Out (score a maximum of 7), while others might be removed all together. It pays to check. MyMipsScore app has the built-in ability to analyze the benchmarking for every Clinical Quality Measure.
The Case Minimum remains the same (at least a denominator of 20 patients), however, the Data Completeness (percent of patients that you apply to each measure), has gone up from 60% to 70% in 2020.
6. Determine the Best Collection Type to Maximize Your Quality score
CMS allows CQMs to be submitted from data collected by EHRs (eCQMs), by Registries (MIPS CQMs) or by Claims. Any combination applicable to your organization will be accepted by CMS.
Some measures that fit your Organization can only be submitted via a Qualified Registry and you will lose valuable points if you exclude those measures. For instance, consider measures 126 and 127:
126 - Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy - Neurological Evaluation
127 - Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention - Evaluation of Footwear
7. Determine the Improvement Activities that Best Fits Your Organization
Select the IAs based on your practice size (15 or fewer provider get double points)
If you select a high value IA, the 20 points get doubled to 40 and you max out the category with one IA.
For 2020 at least 50% of the Group members must enter that they have completed the IA(s). Take this into consideration while determining the best 90 continuous days for your reporting period.
(In 2019, only one member of the Group was required to complete the IA measure to satisfy the criteria.)
8. Evaluate the Registry You Plan to Use
It is very important to know that all Registries are not alike. Determine if they:
Serve only certain members of a given specialty or purchased Membership
Have sign-up deadlines that are very early in the year. Missing the deadline excludes you from that Registry
Do not handle submission for all the performance categories (Quality, PI, IA)
Cover the CQMs that you are reporting on
Can import data in the format(s) available to you
9. Check Your Final MIPS Score for 2019
CMS will publish the Performance Feedback Report for MIPS 2019 in July 2020.
The submission of the data by April 30th of 2020 resulted in a preliminary score. It is preliminary until CMS publishes the Final Score.
If you notice a discrepancy in the score you submitted and the Final Score issued by CMS, you will have 60 days to request a Targeted Review. Failure to request the review will result in the CMS score being published as is and the penalty or limited incentive will stand unchanged.
10. Know the Hardship Exclusion Deadlines
CMS has published the process to claim exclusions for hardships on June 24th, 2020. The deadline is December 31st, 2020. As providers continue to be significantly impacted by COVID-19 throughout the 2020 MIPS performance year, CMS might announce additional criteria modifications or deadline extensions.
Remember the Exceptional Performance Bonus
We hope that you take the Lessons Learned over the past MIPS Performance Year and apply them to formulate the best plan of action for MIPS 2020 and beyond. As of now it is unknown how the COVID-19 crisis will affect MIPS 2020. However, all upside potential for MIPS is not lost. CMS will still have the $500 million in Exceptional Performance bonus for ECs who score between 85.1 and 100 points. Even though the budget-neutral portion of positive payment adjustment might be diminished by clinicians claiming exceptions, it also means that there will be fewer clinicians to share the Exceptional Performance Bonus, so you would receive a bigger portion of that pie. Additionally, your MIPS score and Quality performance will be published on the Physician Compare website providing your practice with a Quality Star Value.
Depending on your MIPS 2020 incentive potential based on estimated 2022 Medicare Part-B payments, is it worth shooting for MIPS Scores > 85? It is for you to decide.
We are available to assist you with MIPS, from guidance to submission.
