MIPS Tips (July)

August 6, 2019

The Merit-based Incentive Payment System (MIPS) 2019 reporting year is approaching the last 90-day reporting period for Promoting Interoperability. Be sure you are staying on track with the changes for 2019 and review the following if applicable to your practice.

12.3 SP3 Upgrades 
Quatris Healthco will announce the release of CPS 12.3 SP3 soon and begin upgrades shortly after that.

2015 CEHRT Compliance for Promoting Interoperability 
Information regarding the 2015 CEHRT Requirements for PI is vital to your success if reporting to the PI category! Because the website is updated frequently, we recommend you review any new information.

  • 2015 CEHRT Requirements on the Quatris Healthco Knowledgebase
    A new resource was added to the Quatris Healthco Knowledgebase and provides step-by-step instructions for providers and practices to take to be fully 2015 CEHRT compliant before starting a 90-day reporting period for the PI category of MIPS. Click HERE to review this new resource! If you do not have access to the Quatris Healthco Knowledgebase REGISTER HERE.

CPS12.3 and 2015 CEHRT Compliance Timing
The timing of your upgrade and the additional 2015 CEHRT requirements that must be in place are dependent upon special statuses and the categories of MIPS that will be reported in 2019.

  • If you are reporting to the Promoting Interoperability category of MIPS then you must have the following completed no later than October 1, 2019:
    • Upgrade to a version of CPS12.3 (preferably 12.3 SP3) 
    • Additional 2015 CEHRT requirements – Azure, API, CCDA 2.1
  • If you are NOT reporting to the Promoting Interoperability category of MIPS but are reporting to the Quality category using athenaPractice and CQR, then you must be upgraded to version of 12.3 (preferably 12.3 SP3) no later than December 31, 2019.
    • The additional 2015 CERHT requirements do not apply for this option as those are only applicable if reporting to the Promoting Interoperability category.
  • To determine if a special status applies to your practice and if you qualify for a Promoting Interoperability Hardship, visit the Exception Applications section of the QPP website. The QPP Participation Look-Up Tool will provide details as to whether or not any special statuses apply at the individual and group levels.

2018 Final Scores Released
On July 3 CMS released the final scores and payment adjustments for the 2018 reporting year via this Quality Payment Program listserv announcement:

“If you submitted 2018 Merit-based Incentive Payment System (MIPS) data, you can now view your performance feedback and MIPS final score on the Quality Payment Program website.”  

You can access your 2018 MIPS performance feedback and final score via this link: cms.gov/login

  • Log-in using your HCQIS Access Roles and Profile (HARP) system credentials (these are the same credentials used to submit your 2018 MIPS data). If you don’t have a HARP account, refer to the QPP Access User Guide to start the process.
  • To learn more about performance feedback, view these frequently asked questions (FAQs). The FAQ’s highlight what is performance feedback, who receives the feedback, and how to access it on the Quality Payment Program website.

Targeted Review period opened with the release of the 2018 final scores and payment adjustments. Information was provided via the July 3rd Quality Payment Program listserv announcement:

“The MIPS payment adjustment you will receive in 2020 is based on your final score. A positive, negative, or neutral payment adjustment will be applied to the Medicare paid amount for covered professional services furnished by a MIPS eligible clinician in 2020.”

MIPS eligible clinicians, groups, and virtual groups (along with their designated support staff or authorized third-party intermediary), including APM participants, may request CMS to review the calculation of their 2020 MIPS payment adjustment factor(s) through a process called targeted review. 

When to Request a Targeted Review
If you believe an error has been made in your 2020 MIPS payment adjustment factor(s) calculation, you can request a targeted review until September 30, 2019. The following are examples of circumstances in which you may wish to request a targeted review: 

  • Errors or data quality issues for the measures and activities you submitted.
  • Eligibility and special status issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment).
  • Erroneously excluded from the APM participation list and not being scored under the APM scoring standard.
  • Performance categories were not automatically reweighted even though you qualify for automatic reweighting due to extreme and uncontrollable circumstances.

How to Request a Targeted Review
You can access your MIPS final score and performance feedback and request a targeted review by:

  • Visiting the Quality Payment Program website
  • Logging in using your HCQIS Access Roles and Profile System (HARP) credentials (these are the same credentials that allowed you to submit your MIPS data.) Refer to the QPP Access Guide for additional details.

When evaluating a targeted review request, CMS may require documentation to support the request. If your targeted review request is approved, CMS may update your final score and the associated payment adjustment (if applicable), as soon as technically feasible. Note: targeted review decisions are final and not eligible for further review.

For information about how to request a targeted review, refer to the 2018 Targeted Review Fact Sheet and the 2018 Targeted Review FAQs.

If you have questions about your performance feedback or MIPS final score, contact the Quality Payment Program via phone 1-866-288-8292/TTY: 1-877-715-6222 or email: QPP@cms.hhs.gov”.  

MIPS Consulting
Quatris Healthco offers quality consulting services to our all of our customers. For information contact mkeller@qhco.com.

*Note: The content of this email may not apply to your practice. Contact your EMR vendor on processes for support and quality reporting programs.

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