If you bill Medicare Part B more than $90,000 in allowed charges per year and provide over 200 covered professional services under the Physician Fee Schedule for more than 200 unique Medicare patients a year, then you are part of the QPP. If you do not meet all three criteria, you could be exempt from participating in the program in 2021 under the the low-volume threshold exemption. Clinicians who meet the low-volume threshold may still opt in to MIPS if they meet at least one criterion.
Eligible clinicians under the program include:
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Physical therapists
- Occupational therapists
- Qualified speech-language pathologists
- Qualified audiologists
- Clinical psychologists
- Registered dietitian or nutrition professionals
If you are unsure if you are required to participate in MIPS, CMS has provided a resource to check your status by entering your NPI into an eligibility “calculator.”
Additionally, the agency plans to send letters to clinicians notifying them of their eligibility in 2021.
Two Tracks: Which is right for you?
There are two participation tracks in the Quality Payment Program. Most Medicare Part B clinicians and groups will fall under the Merit Incentive Payment System (MIPS) track, while a smaller percentage will qualify to participate in the Advanced Alternative Payment Models (APM) track if considered an “advanced APM.” It is important to note that those APM models which are not considered “advanced” by CMS will still participate in the MIPS track.
Learn more about APMs here.
The MIPS Track
You will receive a performance-based adjustment to your Medicare fee schedule in 2023 based on your performance in 2021. The amount of the adjustment, either positive, negative, or neutral, is based on an eligible clinician or group’s Composite Performance Score (CPS). The CPS is calculated using data across four categories of measurement:
- Promoting Interoperability
- Improvement Activities
How do I avoid a negative payment adjustment?
With the “pick your pace” program, clinicians submit just 90 consecutive days of performance data for the required measures in the Improvement Activities and Promoting Interoperability categories. However, clinicians need to report data on all required measures in the Quality category for the full performance year (12 months).
CMS will also score and measure the Cost category for the full 12 month period as well. Since CMS gathers the Cost category information through Medicare claims data, no additional submission mechanism is required. If you do not participate in MIPS in 2021 you could be faced with a 9% penalty.
Individual vs. Group Reporting
Eligible clinicians have the option to report as an individual, within a group, or within a virtual group.
An individual is a single National Provider Identifier, or NPI, tied to a single Taxpayer Identification Number, or TIN.
A group is a single TIN with two or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their NPIs, who have reassigned their Medicare billing rights to the TIN. Participants are scored as a group and receive one payment adjustment based on aggregate performance.
A virtual group is a combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of ten or fewer eligible clinicians that elect to form a virtual group for a performance period for a year. There is currently no limit on the number of TINs that can participate in a virtual group. Virtual Groups bring additional flexibility to the program, allowing clinicians to participate in MIPS with their peers, regardless of their geographical proximity or specialty. Those wishing to participate in a MIPS Virtual Group must make a formal election with CMS by December 31, 2021.
Data for participants can be reported by various submission types by an individual or group as applicable. Alternatively, data may be reported by a Third Party Intermediary that submits data on measures and activities on behalf of a MIPS eligible clinician or group.
Selecting and Reporting Measures
The aim of the MIPS program is to provide clinicians and groups with the flexibility to select measures that best suit their practice. For the Quality category, participants can choose from several types of measures, which vary based on whether they are reporting as individuals or as part of a group. Submission methods are dependent on the types of measures chosen.
For the Improvement Activities and Promoting Interoperability categories, participants choose their measures from the QPP website. There are three submission methods for these measures.
- Direct: Users transmit data through a computer-to-computer interaction such as an API.
- Log-in and upload: Users log in with a set of authenticated credentials and upload and submit data in a CMS-specified format.
- Log-in and attest: Users log in with a set of authenticated credentials and manually attest that certain measures and activities were performed.
Eligible clinicians are required to report six measures of their choosing for the Quality category. One of those measures must be an outcome measure. If no outcome measure is available, a ‘high priority’ measure must be reported in its place. High priority measures are contained in the following domains: outcome, appropriate use, patient safety, efficiency, patient experience, efficiency, and care coordination.
What are specialty measurement sets?
CMS developed specialty measure sets as a part of the available MIPS measures in the Quality Category. Participating clinicians must choose six measures to report within their specialty set. If there are fewer than six Quality measures to choose from in a specialty set, the clinician or group must complete all available measures contained in the set.
For anesthesia clients
SurveyVitals can help anesthesia clients who utilize a Qualified Clinical Data Registry (QCDR) meet a measure–AQI 48 (anesthesia patient experience)–in the Quality performance category. Learn more here.
The IA category requires clinicians to participate in a combination of measures totaling 40 points to fully satisfy reporting requirements. Activities weighted “high” are worth 20 points, while “medium” weighted activities are valued at ten points. Clinicians and groups considered non-patient facing, and practices with 15 or fewer eligible providers and/or clinicians practicing in rural and health professional shortage areas, may face reduced reporting requirements. Learn more about these special exemption statuses here.
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.
The Promoting Interoperability category places an emphasis on interoperability and patient engagement with certified EHR technology. Eligible clinicians must report on certain measures from four ‘objectives,’ or claims exclusions if applicable. Scoring is performance-based at the individual measure level, for a total of up to 100 points. In 2021, organizations must use the 2015 Edition CEHRT.
Clinicians and groups considered non-patient facing, and practices with 15 or fewer eligible providers and/or clinicians practicing in rural and health professional shortage areas, may face reduced reporting requirements. Watch the video below to learn more.
Anesthesia QCDR Reporting
SurveyVitals can help anesthesia clients who utilize a Qualified Clinical Data Registry (QCDR) meet a measure–AQI 48 (anesthesia patient experience)–in the Quality performance category. We currently support NACOR (Anesthesia Quality Institute), Anesthesia Business Group, and Anesthesia Quality Registry (Provation). Learn more here.
What are the current MIPS dates and deadlines?
- January 1, 2021:2021 performance year begins
- January 4, 2021: Data submission period for the 2020 performance year begins
- March 31, 2021: Data submission for the 2020 performance year closes
- July 2021: CMS provides performance feedback based on submissions for the 2020 performance year
- October 3, 2021: Last day to begin the continuous 90-day performance period for Improvement Activities
- December 31, 2021: Last day to make a virtual group election for the 2022 performance year
- December 31, 2021: 2021 performance year ends
- January 1, 2022: Payment adjustments from the 2020 performance year go into effect
How is MIPS different in 2021?
To learn about the changes to the MIPS program from 2020 to 2021, see our article
on the 2021 updates.
Does SurveyVitals administer CAHPS for MIPS?
Yes! SurveyVitals is a CMS-approved vendor
ready to administer CAHPS for MIPS on behalf of your organization in 2021. The CAHPS for MIPS survey can be used to satisfy one Quality measure or one Improvement Activity.
Interested in meeting measures with SurveyVitals?
Want to learn how SurveyVitals can help you prepare for MIPS? Subscribe to our MIPS update list below or email us at firstname.lastname@example.org
. You can also send us a message using the blue chat icon below to speak to a member of our support team.