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.
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.
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.
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.
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.
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.
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.
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.
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.
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.CMS, Improvement, improvement activities, macra, MIPS, QCDR, QPP, Quality, quality category, quality payment program
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.
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.
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.
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.
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|
CMS has released the final rule for MIPS 2020. Read the key takeaways here.
If you’re participating in MIPS, you’ll need to know about the changes to the program in 2020. This week, CMS released the Quality Payment Program proposed rule for the next performance year. While their goal is to maintain many of the requirements from the 2019 performance year, there are some updates to the MIPS track. Here are the highlights of the proposed changes.
In 2020, the 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.
The maximum negative payment adjustment will increase from -7% to -9% in 2020. Positive payment adjustments (not including exceptional performance) will increase from 7% to up to 9%.
The performance threshold–the minimum number of points to avoid a negative payment adjustment–will increase from 30 points in 2019 to 45 points in 2020. The exceptional performance threshold, which determines additional positive payment adjustments, will increase to 80 points in 2020.
A full breakdown of proposed MIPS changes can be found in the table below. CMS is accepting feedback on the proposed rule at regulations.gov through September 27, 2019 with the file code CMS-1715-P.
CMS has also proposed larger changes to the program starting in 2021. Click here to read our summary of their new proposed framework.
For more information on the current MIPS performance year and how SurveyVitals can help you fulfill your requirements, visit our MIPS page or chat with us using the blue chat icon below.
|Policy Area||Current Year 3 (Final Rule CY 2019)||Year 4 (Proposed Rule CY 2020)|
|Performance Category Weights||
|Quality Performance Category||Data Completeness Requirements
CMS seeks measures that are:
There is no formal policy for measure removal, as QCDR measures must be submitted for CMS approval on an annual basis as part of the self-nomination process.
|Data Completeness Requirements
In addition to current requirements:
In addition to current measure removal criteria:
In instances in which multiple, similar QCDR measures exist that warrant approval, we may provisionally approve the individual QCDR measures for 1 year with the condition that QCDRs address certain areas of duplication with other approved QCDR measures in order to be considered for the program in subsequent years. Duplicative QCDR measures would not be approved if QCDRs do not elect to harmonize identified measures as requested by CMS within the allotted timeframe.
QCDR Measure Rejections
|Improvement Activities Performance Category||Definition of Rural Area
Rural area means a ZIP code designated as rural, using the most recent Health Resources and Services Administration (HRSA) Area Health Resource File data set available.
Patient-Centered Medical Home Criteria
MIPS eligible clinicians who successfully participate in the study receive full credit in the Improvement Activities performance category.
Removal of Improvement Activities
Requirement for Improvement Activity Credit for Groups
|Definition of Rural Area
Rural area is proposed to mean a ZIP code designated as rural by the Federal Office of Rural Health Policy (FORHP) using the most recent FORHP Eligible ZIP Code file available.
Patient-Centered Medical Home Criteria
Please review Appendix 2 in the CY 2020 NPRM for a comprehensive look at the changes proposed to the inventory.CMS Study on Factors Associated with Reporting Quality Measures
Study year 2019 (CY 2019) is the last year of the 3-year study, as stated in CY 2019 PFS final rule (83 FR 59776). CMS will not continue the study during the 2020 performance period. Final study results will be shared at a later date.
Removal of Improvement Activities
|Promoting Interoperability Performance Category – Hospital-Based MIPS Eligible Clinicians in Groups||
A group is identified as hospital-based and eligible for reweighting when 100% of the MIPS eligible clinicians in the group meet the definition of a hospital-based MIPS eligible clinician.
A group would be identified as hospital-based and eligible for reweighting if more than 75% of the NPIs in the group meet the definition of a hospital-based individual MIPS eligible clinician.
For non-patient facing groups (more than 75% of the MIPS-eligible clinicians in the group are classified as non-patient facing) we would automatically reweight the Promoting Interoperability performance category.
No change to definition of an individual hospital-based MIPS eligible clinician.
|Promoting Interoperability Performance Category||Objectives and Measures
||Objectives and Measures
|Cost Performance Category||Measures
|Final Score Calculation: Performance Category Reweighting due to Data Integrity Issues||
|Performance Threshold / Additional Performance Threshold / Payment Adjustment||
MIPS eligible clinicians and groups may submit a targeted review request by September 30 following the release of the MIPS payment adjustment factor(s) with performance feedback.
All requests for targeted review would be required to be submitted within 60 days of the release of the MIPS payment adjustment factor(s) with performance feedback.
Eligible clinicians under the program include:
|*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.|
blake March 13th, 2019 Categories: Ambulatory and Outpatient Surgery, Anesthesia, CAHPS Surveys, Emergency Medicine, featured, MIPS Information, Neonatology, Outpatient Practice, Radiology, Urgent CareTags: APM, CAHPS, cost category, improvement activities, macra, MIPS, Performance Year, promoting interoperability, QCDR, QPP, quality category, quality payment program
Are you an anesthesia provider participating in the Merit-Based Incentive Payment System (MIPS)? Let us tell you how the SurveyVitals solution might help you fulfill certain reporting requirements.
The Merit Incentive Payment System (MIPS) is one of two tracks in the QPP, the quality payment incentive program implemented by CMS. A small percentage of clinicians will qualify to participate in the Alternative Payment Models (APM) track, but most anesthesiologists will fall under the MIPS track.
You will receive a performance-based adjustment to your Medicare fee schedule in 2022 based on your MIPS performance in 2020. 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.
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 2020 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.
To determine 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.”
Anesthesiologists have the option to report as an individual, within a group, or within a virtual group.
|Individual||Single NPI tied to a single Tax Identification Number (TIN)|
|Group||Single TIN with two or more eligible clinicians, including at least one MIPS-eligible clinician, as identified by their National Provider Identifiers (NPIs), who have reassigned their Medicare billing rights to the TIN|
|Virtual Group||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|
Reporting mechanisms vary based on reporting type and measure category. You can find more information on reporting mechanisms here.
Anesthesia providers and groups can select measures from the list of CMS-approved MIPS measures at the QPP website. Alternatively, they may select to report on Quality performance using specialized measures developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDR measures must be approved each year by CMS.
Anesthesiologists are required to report on six measures of their choosing for the quality category. One of those measures must be an outcome measure.
SurveyVitals is equipped to help anesthesia clients utilizing a QCDR to meet an outcome measure (AQI 48 – Patient-Reported Experience with Anesthesia) in the Quality category. You must sign a disclaimer in order to report your patient experience data to a QCDR. View the reporting checklist, quick facts, and important deadlines here.
Anesthesia providers are required to participate in a combination of IA measures totaling 40 points. “High-weighted” activities are worth 20 points, while “medium-weighted” activities are valued at ten points. Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at email@example.com to learn more.
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.
Reporting requirements for Improvement Activities are reduced for non-patient facing clinicians, which are defined as either:
Those considered non-patient facing must participate in one high-weighted activity or two medium-weighted activities to satisfy the Improvement Activities category (for a total of 20 points rather than 40).
Always remember to check the eligibility calculator on the QPP website to confirm you are considered non-patient facing.
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 2020, organizations must use the 2015 Edition CEHRT.
The score for the Cost category is calculated using administrative claims data. No data submission is required.
SurveyVitals can help you meet one Quality measure and fulfill the entire Improvement Activities category. Reference the table below to see which measures we can help you meet.
|MIPS Category||Measures We Support||More Information|
|Quality||AQI 48 (Outcome)||Anesthesia QCDR Reporting|
||Improvement Activities Roadmap|
Want to learn how SurveyVitals can help you prepare for MIPS? 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.
*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.anesthesia, anesthesiologist, CRNA, improvement activities, macra, MIPS, QPP, quality category, quality payment program
View up-to-date information on our MIPS resource page here!
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:
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.
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:
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.
Submission methods may vary based on the measure.
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 email@example.comCMS, macra, MIPS, QPP, reporting deadline
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