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P3Care Investigates: QPP MIPS 2021 Proposed Rules

CMS (The Centers for Medicare and Medicaid Services) released the proposed rule for QPP MIPS 2021 via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

In this article, we dissect changes that are expected to appear in MIPS 2021. However, keep in mind that the changes are just proposed until now and are not final yet.

Each year, CMS proposes various guidelines to facilitate physicians with their payments.

How MIPS consultants take care of the administrative data to report to the authorities affects revenue cycles. How to report MIPS data is what add to your revenue year after year, especially for clinicians associated with Medicare.

Physicians Services Translate into Patient Care

As physicians, your first responsibility is towards your patients. For a fact, you would not have time to manage the MIPS reporting 2021 requirements, given the situation with COVID. With all of what’s going on, I am sure you want to begin 2021 on a high note. The help of MIPS consulting services, make the process of MIPS data submission easier and less hectic.

Besides accurate data reporting, we also have to understand the QPP MIPS requirements every performance year.

What can we expect in the MIPS 2021, and how it will impact the data submission process.  Let’s follow-through.

But, first, we must analyze the COVID-19 Impact!

2021 QPP MIPS might come with challenges. We can expect time delays (which we also experienced during MIPS 2020 performance period).

The implications of the pandemic are going to go a long way with us. For instance, CMS asks physicians to focus on the quality of care rather than the volume of patients. However, with the pandemic, there was no choice left other than catering to the volume of patients while being careful and value-driven to every extent possible.

Therefore, a delay in the implementation of MIPS Value Pathways (MVPs) for 2021 seems only reasonable.

Additional reporting flexibilities are also in consideration in response to the COVID-19. Talk about MIPS incentives, they are by far the most as compared to the previous years. Realistically speaking, P3Care can get you up to +5% positive payment adjustments for its clients. Fill the form that appears in the pop-up and we’ll get back to you shortly.

MIPS Value Pathways (MVPs)

The proposed rule stated that MIPS Value Pathways (MVPs) will be delayed until 2022.

However, they will be available as options, and eligible clinicians can choose to report through them alongside the other MIPS data submission options.

APM Performance Pathways

Participants of MIPS APMs are allowed to report via APPs, which function the same as MVPs.

CMS is also considering sunset the current APM score standards in 2021.

Keep in mind that only the following audience can use APPS.

  • Individual eligible clinician
  • Group (TIN) or APM Entity
  • MIPS APM participants

The above-mentioned specialists have the option to use APP, but it is compulsory for ACOs participating in the Medicare Shared Savings Program to report quality performance via the APP.

The performance category for the APP will be scored as follows upon the fixed set of quality measures.

Quality Category: Weighs 50%. It contains six measures that focus on population health.

Improvement Activities (IA) Category: Weighs 20%. CMS will automatically assign its score based on the requirements of the MIPS APM.

All APM participants reporting through the APP will earn a 100% score for 2021.

Promoting Interoperability (PI) Category: Weighs 30%. Compulsory for all QPP MIPS data submissions.  It is reported and scored at the individual or group level.

Cost Category: Weighs at 0%

Moreover, it is also automatically used for the Medicare Shared Savings Program (MSSP) quality scoring.

QPP MIPS Program Updates

For MIPS 2021, various data submission options will be given to MIPS consulting services to help eligible clinicians get through the program.

Physicians have the option to report QPP MIPS as:

  • Virtual Group
  • Solo eligible Clinicians
  • Group
  • APM Entity

Note that the virtual group has the highest hierarchical priority when CMS receives multiple scores for it.

APM Participation

Participation through APM participation is available for eligible clinicians. They can report QPP MIPS data for both Quality and Improvement Activities (IA) performance categories.

Moreover, you can select and report MIPS Quality measures in the same manner as eligible clinicians choose and report for QPP MIPS.

However, generally, the APM Entity group calculates the performance for the Improvement Activities (IA).

The Cost category has a slight change in the data reporting mechanism. If you do not report this category via APP, the APM Entity Group will automatically score it.

The above-mentioned are the little details that QPP MIPS participants must know beforehand they enter the MIPS 2021.

Until now, you must have a good idea of the minor changes that are expected in QPP MIPS 2021. Now, it’s time to look into details of (Centers for Medicare and Medicaid Services) CMS-published Proposed Rule. Some adjustments are made to simplify administrative data while others in response to the corona pandemic.

Let’s get started!

Proposed Sunset of Web Interface Mechanism

CMS in the Final Rule aims to facilitate groups and virtual groups with MIPS data submission 2021. They proposed a sunset of the CMS Web Interface as a new reporting method.  It is particularly useful for larger group participants of QPP MIPS 2021, APM (Alternative Payment Model), and the MSSP (Medicare Shared Savings Program).

It is because of the CMS data indicating a 45% reduction in the usage of the mechanism. Moreover, there is a 40% reduction in utilization of CMS Web Interface.

If this rule comes into effect, MIPS eligible groups and virtual groups can then report relevant data via a MIPS Qualified Registry or EHR (Electronic Health Records).

Crucial Changes in APM Reporting

Many APM participants may use APP (APM Performance Pathway) for quality reporting.

CMS also suggests setting six quality measures for APM reporting naming:

  • Controlling High Blood Pressure
  • Diabetes: Hemoglobin A1c Poor Control
  • Preventive Care and Screening: Screening for Depression and Follow-up Plan
  • Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs
  • Hospital-Wide, 30-day, All-Cause Unplanned Readmission Rate for MIPS Eligible Clinician Groups

This step aims to simplify the administrative load to help focus physicians on quality patient outcomes.

ACO (Accountable Care Organization) Reporting

Under QPP MIPS 2021, the proposed rule suggests Shared Savings ACOs reporting with the following changes.

There is an availability of several data submission methods for ACOs stating who will submit what data to CMS. For Instance, instead of the ACO entity submitting data by itself, allowing participants to submit data at the individual level.

The operational and strategic changes will allow ease in the reporting process. Of course, data collection and aggregation is a problem that often hinders the pace of MIPS reporting. However, with this step, we can observe potential improvement in data submission and the MIPS score.

How to Adjust with the Changes in MIPS Data Submission Process?

Here to remember that the proposed rule might be different from the final rule. But, even if the reporting requirements changes, they must be somewhat similar. The best option is to get in touch with professional MIPS consulting services to comply with the required changes.

Conclusion

QPP MIPS 2021 is different from the previous years in terms of quality reporting. The pandemic is still not over yet, and the focus on patient empowerment through value-based outcomes has increased noticeably.

We also understand that adjusting to new reporting requirements takes time. However, the comprehension process of MIPS reporting 2021 criteria becomes easy when you have professional MIPS consultants with you.

To begin with, medical practices should design their strategic goals to align their efforts. It is just the start of the performance year, so you can experiment with different measures. It is an opportunity to compensate for the lost revenue during the pandemic emergency by delivering QPP MIPS 2021 performance. We should not miss it.

CM

P3Care and Trump Administration Encourage Practices to Reopen

America should adopt smarter ways to counter COVID-19 as it reopens for patients and clinicians. In the meanwhile, CMS has come up with a guide for patients and beneficiaries as they decide to visit providers for in-person care.

As a result of the surge in COVID-19 patients, many providers were left with no option except to restrict care at their facility. They had to do that for the essential treatment of COVID-19 patients.

However, with a much-improved situation now, the government encourages private practices and clinics to resume their normal operations. They are to continue with their postponed non-emergency treatments and carry out in-person patient visits as we speak.

The patient guide ensures the safe reopening of healthcare facilities with patients receiving the much needed in-person care. National public health emergency took over, causing this delay in normal appointments, procedures, and treatments.

We can’t thank President Trump enough for his vision, the expansion of telehealth, to be specific, in a very short time. In this way, all this time when America was closed, patients were able to talk to their clinicians from the safety of their homes.

Ms. Seema Verma, Administrator of CMS, reinforces the vitality of in-person care and refers to it as a gold level of care. Such steps by the government are in favor of patients who have long been waiting at homes for procedures, vaccinations, operations, and evaluation of chronic conditions.

She further explained healthcare is the right of every American and our healthcare heroes are working day in and day out to deliver it safely. We should all feel confident when going for in-person care recommended by our providers.

On April 19, CMS issued the first part of recommendations to safely start in-person care activity in areas with a low occurrence or relatively low and constant number of COVID-19 cases. Hence, we move ahead with another set of recommendations.

CMS leaves no stone unturned when it comes to patient and clinician safety as healthcare systems, practices and clinics further enhance in-person care standards. Recommendations include a list of topics to ensure safety regulations are in place for patients and providers including facility measures; testing and sanitation levels; personal protective equipment and stock of supplies; and workforce presence.

The easy access to healthcare for everyone can be restricted to some extent. However, this decision can’t be prolonged due to financial discrepancies.

During the COVID-19 epidemic, healthcare professionals have lost a major amount of revenue as the resources were redirected towards the pandemic response. Now as the Trump administration is asking to bring normalcy in the economy under strict SOPs, we can expect a gradual balance between expenses and revenue.

As it was with part 1 of recommendations, decisions to reopen should be in line with federal, state, and local rules, CDC’s guidance, and association with the state and local public health authorities.

As the country continues to move on the path of reopening, patients have concerns about when to check-in with their providers for in-person visits.

CMS also acts as a guide with empathy for patients to make the right decisions as they prepare to meet their providers in person. Ultimately, it is in their best interest to follow the new rules.

Find guidelines for patients for in-person visits in English here: https://cms.gov/files/document/covid-what-patients-should-know-about-seeking-health-care.pdf and in Spanish here: https://www.cms.gov/files/document/covid-what-patients-should-know-about-seeking-health-care-spanish.pdf

To read one of the previous updates, go here – P3 investigates: Trump Administration plans to reopen nursing homes

To read about the work of the White House Coronavirus Task Force reaction to COVID-19, go to www.coronavirus.gov. For specific information about CMS, keep reading our blog updates.

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CMS Issues Guidelines for the Nonessential Medical Procedures

COVID-19 has taken over the world. The coronavirus emergency has become so big that the regular medical procedures have taken a back seat until the situation gets any better.

CMS – The Centers for Medicare and Medicaid has announced that all the nonessential surgical, diagnostic, and dental procedures should be delayed during the novel corona outbreak.

The reason for it is that the number of corona-affected patients are increasing and so is the demand for more doctors. As the physicians are participating in the fight against the pandemic, it is difficult for them to continue with the regular procedures. Moreover, they can also save on their personal safety equipment, tools, ventilators, and beds.

On the other hand, amidst the coronavirus lockdown, it would be difficult for medical billing services to compile claims when their resources can be used to document hundreds of cases of COVID-19.

CMS admits that this step will be helpful to treat those, who are more in need of quality healthcare. The coronavirus spread can only be limited when everybody takes charge of his safety and others around him. A conclusive step towards a corona-free nation would be that clinicians advise their patients to stay at home unless absolutely necessary to minimize their risk of virus exposure.

They should encourage patients to follow the government guidelines to slow down or contain the risks of COVID-19.

The Impact of Limiting Regular Medical Procedures

Medical billing services, medical billing companies

The CMS-issued recommendations already come with an implementable plan for hospitals and medical practices for immediate COVID-19 response action.  The organization has also touched upon factors in which physicians may postpone nonessential surgeries.

The factors include:

  • Patient risk factor leading to the urgency of medical procedure
  • Availability of equipment/ beds/ staff

The recommendations will be compliant to assist emergency patients and save resources for corona effects. The decision to proceed with the dental, medical, and surgical procedures will be taken by the local clinician, patient, hospital, state, and local health departments.

All of these actions taken to assist medical billing services and clinicians are part of the White House Task Force efforts.

What the Bigger Picture Looks Like?

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Doctors and other healthcare staff are under great threat of having COVID-19. They are acting as front liners due to their nature of jobs. The recommendations will also be a step towards their safety. Ultimately, every healthcare organization has to implement these strategies so that, we don’t face handling the worsening situation with limited resources.

American Medical Association (AMA) also appreciates this step by CMS. In this way, healthcare organizations will be preparing for COVID-19 patients efficiently. Whereas, healthcare leaders will be strategizing to better support physicians and patients.

CMS offers much flexibility in its program for healthcare providers to consider the benefits of this suggestion. Medical billing companies can also manage their duties accordingly.