There are a lot of questions from providers about where CMS says one must report both Medicare and non-Medicare patient data. The requirement can be found under the Data Completeness requirements in the final rule. Here are some citations:
§ 414.1340 Data completeness criteria for the quality performance category (page 77542 of Federal Register Notice, Friday, November 4, 2016):
(a) MIPS eligible clinicians and groups submitting quality measures data using the QCDR, qualified registry, or EHR submission mechanism must submit data on:
(1) At least 50 percent of the MIPS eligible clinician or group’s patients that meet the measure’s denominator criteria, regardless of payer for MIPS payment year 2019 (MIPS PY2017).
(2) At least 60 percent of the MIPS eligible clinician or group’s patients that meet the measure’s denominator criteria, regardless of payer for MIPS payment year 2020 (MIPS PY2018).
CMS also noted the following response in the final rule regarding data completeness on page 77123 of the Federal Register Notice:
Response: We can appreciate the concerns raised by the commenter. We are continuing to use a 50 percent data completeness threshold similar to what was used under PQRS. We do note however that under MIPS the data completeness threshold applies for both Medicare and non-Medicare patients.
We are finalizing our approach of including all-payer data for the QCDR, qualified registry, and EHR submission mechanisms because we believe this approach provides a more complete picture of each MIPS eligible clinician’s scope of practice and provides more access to data about specialties and subspecialties not currently captured in PQRS.