MIPS Reporting - A Deeper Dive into Quality

Posted on October 29, 2018

A Focus on Quality Reporting 

MIPS eligible clinicians and groups must achieve 15 MIPS points in 2018, out of a possible 100 points, to avoid the automatic 5% penalty in 2020. Earning over 15 points can result in a possible positive payment adjustment, so the more points you earn the better.

The Quality component of MIPS has the highest weight of all 4 MIPS categories, counting towards half of your total MIPS score. This means you can earn a maximum of 50 points for this category alone, as long as you fully report and depending on your performance for each of the measures. Let’s take a closer look at what you need to do to successfully report Quality.

Getting Started - Select Your Measures

There are over 270 Quality measures to choose from across all specialties. MIPS eligible clinicians and groups should select 6 Quality measures that are most relevant to your practice, or choose to report a Specialty Measure set established by CMS. In order to maximize your points in this category, at least 1 of the 6 measures should be an Outcome measure, or a High Priority measure if an applicable Outcome measure is not available.

You can find a full list of all 2018 Quality measures here or view measures recommended for your specialty here.

Understanding How To Report Each Measure

When selecting which measures to report, it’s important to understand the CMS criteria for each measure. First, determine if you have eligible patients to report. Each measure has “denominator” criteria which is used to identify the intended patient population. The “denominator”, or eligible patient population, is generally based on CPT/HCPCS billing codes, diagnosis codes and other demographic criteria (e.g., gender and/or age requirements). If you don’t submit claims with the required billing or diagnosis codes associated with a measure, you won’t have eligible patients to report for that measure.

Another important factor to consider when selecting Quality measures is how often a measure gets reported. Each measure will contain “instructions” which indicate the reporting frequency. Some measures are only reported once per reporting period, while others are reported for each eligible visit (e.g., Measure #130, Documentation of Current Medications).

Finally, some measures are designated as “inverse” measures, which means a lower calculated performance rate equals better clinical care. In these cases, a performance rate closer to 0% is better and will result in more MIPS points. For inverse measures, a rate of 100% means all of the denominator eligible patients did not receive the appropriate care or were not in proper control.

*Remember, the CMS criteria will vary from measure to measure, so it’s a good idea to take a close look at each measure to ensure you stay on track with your reporting.

Meeting Data Completeness Requirements

For 2018, Quality measures must be reported for the entire performance year - January 1, 2018 to December 31, 2018. This is an increase from 90 days in 2017. CMS also requires that each Quality measure meet data completeness requirements, meaning your measures must be reported on at least 60% of eligible cases for the entire year (up from 50% in 2017) for both Medicare and non-Medicare patients.

Maximizing Your Quality Score

Each measure that meets the data completeness and case minimum requirements (at least 20 patients reported), and can be compared against a national benchmark, can earn between 3 and 10 points. CMS has made an exception for 6 “topped out” measures that can earn a maximum of 7 points this year (measures 21, 23, 52, 224, 262 and 359).

Measures that don’t have national benchmarks or meet the case minimum requirements (at least 20 patients reported) would only receive 3 points. Additionally, measures that don’t meet the data completeness standard would only receive 1 point for large practices (16 or more in the TIN) and 3 points for small practices (15 or less in the TIN).

Quality Bonus Points

There are a couple of ways you can earn bonus points in the Quality category:

  • If you submit 2 or more Outcome or High Priority measures (beyond the initial one required), you will earn additional points for those measures. Each additional Outcome measure is worth 2 bonus points, while each additional High Priority measure is worth 1 bonus point. A quality measure must have a performance of greater than 0, be reported on at least 60% of eligible cases for the year, and have at least 20 patients reported to be eligible for the bonus points.
  • You will receive 1 bonus point per measure for End-to-End Electronic Reporting (ETE) reporting. ETE means your quality data is reported directly from your EHR to our registry.

*Bonus points for reporting additional Outcome/High Priority measures or for ETE reporting are capped at 10% of your Quality score.

Improvement Scoring

Beginning in 2018, providers can also earn up to 10 points in the Quality category based on the rate of improvement compared to their 2017 performance. Clinicians would be eligible for these bonus points if they meet the following criteria:

  • Fully participate in the Quality category for the current performance period (e.g., submit 6 measures, with at least 1 Outcome or High Priority measure, and all measures meet data completeness requirements).
  • Data sufficiency standard is met meaning, there is data available and can be compared.

If CMS can’t compare data between two performance periods, or there is no improvement, the improvement score will be 0%.

Reporting More than 6 Measures

For clinicians and groups who report more than 6 measures, CMS will select the highest scoring Outcome measure first (or the highest scoring High Priority measure if an Outcome measure is not available), then the next 5 highest scoring measures. CMS will include any bonus points from the remaining measures as long as they don’t exceed the 10% cap.

Reporting Less than 6 Measures

If you or your group submits data on fewer than six quality measures, or fails to submit an Outcome or High Priority measure, CMS will conduct an eligibility measure applicability (EMA) process to identify clinically-related measures you could have submitted. The EMA analysis applies only if you submit data through claims or a qualified registry, and if you submit less than the required quality measures for a program year. More information about the EMA process can be found here.

Approaching the Finish Line

As the end of the 2018 MIPS performance year draws near, it’s not too late to get started with your Quality reporting. The Quality category will count towards 50% of your total MIPS score this year, so you want to ensure you understand the requirements and are reporting your measures correctly. For 2018, your Quality measures should be reported on at least 60% of eligible cases for the entire year. At least 1 of your 6 Quality measures should be an Outcome or High Priority measure.

Many clinicians have asked what is the most efficient way to collect their Quality data. We understand flexibility is important, so MDinteractive offers a variety of data input options to make it as simple as possible for your practice. Contact one of our MIPS specialists today to discuss your options and get started with your reporting.

MACRA MIPS Reporting Quality Reporting Quality Measures

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