With the release of the 2017 Final Rule, read our latest post on scoring the MIPS Quality Performance Category.
The Final Rule has good news for the Quality Performance Category.
There are a few important things to remember when thinking about how best to succeed in MIPS. First, unlike PQRS, MIPS is not a pass/fail program. Performance at any level counts. Second, the determining factor in whether a provider receives an incentive or a penalty on their 2019 Medicare Part B fee-for-service payments is how their Final Score in 2017 compares to the threshold set by Medicare. Fortunately, there are a variety of ways to reach that Final Score threshold.
In the first year of MIPS, the Quality Performance Category is worth 60% of a clinician’s Final Score. This makes the quality category an excellent place to start when thinking about how to succeed in MIPS.
Despite the many similarities to the PQRS program, the Quality Performance Category is much closer to looking like PQRS and Value-Modifier (VM) combined. With the introduction of VM, how well a provider performs is important, and MIPS has retained that emphasis on performance.
The Quality Performance Category is actually made up of two sub-categories: CMS-calculated measures and provider-submitted measures.
Provider-submitted quality measures
The measures will look very similar to the measures under PQRS. Though, instead of nine measures in three National Quality Forum (NQF) domains, clinicians are required to report:
- 6 quality performance measures, including;
- 1 outcome measure or another high-priority measure if there is no eligibility for an outcome measure
- There are bonus points for additional high-priority measures and end-to-end electronic reporting.
- NOTE: A cross-cutting measure is no longer required.
Although there are six provider-submitted measures, failing to submit all six does not automatically result in a Final Score below the threshold. The performance on each measure will be translated to a number of points.
Providers with measure eligibility who report fewer than six measures, will receive no points for the missing measures, resulting in a lower quality performance score and thus a lower Final Score.
The first year of MIPS has been labeled a “Transition Year” and has a Final Score threshold of just three points to avoid a penalty. This makes it extremely easy to avoid a penalty by reporting just one quality measure for one patient. Depending on how well a provider performs in the reported measures and within the other MIPS categories, it is also easy to earn some incentive by “full participation” in MIPS, reporting all six measures, and meeting the “completeness criteria”: 50% of eligible patients for a period of 90-days for all payers.
The completeness criteria in the proposed rule was 90% of patients, all payers, full year and was probably the most controversial change from PQRS. With this much less stringent completeness criteria, it makes it possible for even small practices to be successful, even if they have to abstract charts.
Providers are encouraged to submit a full year of data, but it is not a requirement for incentive.
The third point to remember is the provider- submitted measures represent only six of a possible seven measures that go into a provider’s quality performance score for 2017. Depending on practice size, an additional measure will be calculated by CMS from claims data: All-Cause Hospital Readmission. This measure is currently reported to providers in their Quality Resource Use Report (QRUR) and used by the Value Modifier (VM) program.
CMS wants providers to focus on and report measures which are significant to their practice. The decrease from nine to six measures, allows providers to focus on more meaningful measures.
Some measures have such a high performance rate across all providers that they are deemed to be “topped out.” The proposed rule had suggested different scoring for these measures. That scoring for topped-out measures has been dropped for 2017, but watch for a reappearance of different scoring for topped out measures in 2018.
The Final Rule also emphasizes the value of reporting on outcome measures. In 2017 providers will be required to report one outcome or other high-priority measure if no outcome measure is applicable. Although no timeline is presented, the rule mentions the number of high-priority measures expanding in future years. For more information on the 2017 MIPS Quality category measures and which are outcome and high-priority measures download our guide.
This eBook will help you prepare for the transition to MIPS and APMs.