A Deep Dive into the MIPS Quality Category

You've been hearing a lot about MIPS lately. It seems that everywhere you look someone has an eBook or a webinar that will reveal all of the secrets to successfully submitting to MIPS with one convenient, easy-to-digest piece of content. But is anyone really telling you anything you don't already know?

Well, in this article we dig quite a bit deeper into one specific category of MIPS; the Quality category.

If you aren't quite ready for the deep dive, you can however check out our Beginner's Guide to MACRA. Like we mentioned above, this eBook is only an overview meant to get you started with understanding the program.

Let's start with the easy stuff. As everyone knows by now, CMS has released a new program called the Quality Payment Program. One of the tracks for successful completion of this program is the Merit-based Incentive Payment System (MIPS). And one of the categories of MIPS is the Quality category which replaces the PQRS program you have become familiar with.

That's the good news – it will be easy to know what you are reporting under this category of MIPS – quality measures and performance. MIPS is different in a few ways.

What's the difference between PQRS and Quality?

• The level of performance reported to CMS really matters.
• At least one outcome measure must be reported.
• There are many numbers and mathematics that you need to understand to score big on MIPS.

The clinicians who are eligible to participate in MIPS has expanded from physicians only to include Nurse Practitioners, Physician Assistants, Certified Registered Nurse Anesthetists and Clinical Nurse Specialists.

Now, ask yourself these questions:

1. Under how many Tax IDs do your providers submit claims to CMS?
2. Have all of your ECs reassigned their billing rights to one Tax ID or is there more than one Tax ID that will be reporting MIPS to CMS?

ECs can submit as individuals across all MIPS categories or as a group. A group is defined by the Tax ID that their NPI is associated with.

If you choose to report as a group, you will submit data for all categories as a group. This means just one performance per measure for the entire group. The group's fee schedule will be adjusted based on that performance.

6: You need to report a total of 6 quality measures to CMS.

1: You need to submit at least 1 outcome measure unless there is not one available in your specialty measure set. If so, you can report another high priority measure.

15: If you are reporting via the CMS web interface, you need to report 15 quality measures.

The number of measures available for you to choose from depends on the method of reporting you plan to use to submit quality to CMS.

Reporting methods include:

1. Claims – 74 Measures (9 Outcome, 42 High Priority)
2. Registry – 243 Measures (69 Outcome, 158 High Priority)
3. CEHRT – 53 Measures (7 Outcome, 21 High Priority)
4. CMS Web Interface – 15 Measures (3 Outcome, 5 High Priority)

For Qualified Clinical Data Registries (QCDR), the number of measures available depends on what measures the QCDR has been approved for and has implemented.

As you are accustomed to, you will report numerators, denominators, exceptions and exclusions for each measure giving you a performance rate. This year, CMS has published measure benchmarks which reflect performance according to the method of reporting you use. The benchmarks are divided into deciles.

3: For 2017, the lowest decile is decile 3, meaning the lowest performance score you can earn is 3 points. You'll get these points for reporting a measure with at least one patient in the numerator.

10: You can earn from 3 to 10 points for each of the measures that you submit. The score you earn will be based on your performance. That performance score will place you in a certain decile range and that decile will award you between 3 and 10 points.

The level of performance varies for each measure in each decile, so you need to monitor your performance in relation to the deciles in order to have a sense of how well you are doing.

Note: To see the decile range and point association for all measures visit the QPP website education page and scroll down to the link "2017 Quality Benchmarks."

60: The maximum number of points that you can earn for reporting 6 quality measures is 60 points.

15: If your group includes 15 or more clinicians, CMS will calculate the All Cause Readmission measure based on administrative claims data only if there are 200 or more attributed hospitalizations.

If this measure is calculated, an extra 10 points will be added to your Quality point denominator (70) and your level of performance on this measure will be determined by CMS.

If your performance is the best possible for all 6 measures, you will earn 60 points, but should you fall short, CMS has built in the opportunity for you to earn some bonus points.

6: There is a possibility to earn 1 bonus point for each measure reported electronically to CMS, for a total of 6 bonus points for reporting by CEHRT or a reporting vendor, like Medisolv.

6: There is a possibility to earn an additional 6 bonus points by choosing extra outcome or high priority measures beyond the one required outcome measure. An extra outcome or patient satisfaction measure would earn 2 bonus points and for each high priority measure, 1 bonus point is available.

Note: the maximum extra high priority measure points available is 6 points.

Keep these numbers in mind as you carefully select your measures, ensuring that you have included at least 1 outcome measure, measures you have performed well on in the past and a few high priority measures as you compile your 6 measures to be submitted.

Choose your quality reporting vendor and understand how they will support you in the calculation of your possible MIPS points in the Quality category, as well as the Improvement Activities and Advancing Care Information categories.

For more information, please visit medisolv.com/solutions/mips