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MIPS 2020, MIPS consultants, MIPS reporting, MIPS data submission, QPP MIPS, MIPS 2021, MIPS Value Pathways, MIPS consulting services, MIPS Quality measures, QPP MIPS 2020

P3Care Investigates: QPP MIPS 2021 Proposed Rule

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 will be dissecting changes that are expected 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 management.

As a physician, your first responsibility is towards patients. We are sure that you certainly would not have time to manage the MIPS reporting requirements.  However, with the help of MIPS consulting services, the process of MIPS data submission becomes easier and less hectic.

Besides the 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 quality care rather than volume care. 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.

We are expecting a delay in MIPS Value Pathways (MVPs) for 2021.

Additional reporting flexibilities are also in consideration in response to the COVID-19.

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.

CMS updates, QPP MIPS, MIPS Data Submission, MIPS 2020, Eligible physicians, professional healthcare services, QPP MIPS 2020, medical practice

How CMS Determines MIPS Eligibility?

The QPP MIPS participation starts from knowing the eligibility status. For MIPS 2020, clinicians can check eligibility via QPP Lookup Tool. Later on, CMS updates if physicians are eligible for MIPS data submission or not.

However, the reporting requirements change each year due to changed policies. So, if we want to succeed in this program, we have to comply with the changes.

 MIPS 2020 Eligibility Check

According to the official website, interested clinicians must have:

  • National Provider Identifier (NPI)
  • Associated Taxpayer Identification Numbers (TINs)

A TIN is required when you own a practice; belong to a hospital as a medical facility or a medical practice.

In the case of physicians’ reassignment of Medicare Billing Rights to TIN, their NPI gets associated with that TIN, referred to as TIN/NPI combination.

For Instance, if any physician has assigned billing rights to multiple TINs, he/she will have multiple TIN/NPI combinations.

CMS assesses TIN/NPI combination for MIPS eligibility and use TINs for practices’ eligibility.

Eligibility Determination Period of MIPS

CMS looks into past and current Medicare Part B Claims and Provider Enrollment, Chain, and Ownership System (PECOS) data for clinicians and practices, each year twice.

Data analysis from the first segment is referred to as preliminary eligibility. Data from the second review are then attached to the first segment of data and presented for final eligibility determination. The requirement is to pass the Low-Volume Threshold (LVT) during both reviews.

What is Low-Volume Threshold (LVT)?

LVT includes three aspects of professional healthcare services as follows.

  • Allowed charges
  • Number of services provided
  • Number of Medicare patients who receive services

Other than exempt cases, physicians are required to participate in QPP MIPS 2020, if they:

  • Bill above than $90,000 for Part B covered professional healthcare services
  • Check more than 200 Part B patients
  • Offer above than 200 covered professional healthcare services to Part B patients

It is to consider if physicians report Medicare Part B claims in the second review with a medical practice’s TIN, the eligibility status at that practice will only reflect data from 2nd review.

Who Can Participate in MIPS 2020?

CMS has an eligible clinician type. Clinicians falling into the list and satisfying all the requirements can participate in MIPS.

  • Physicians (including doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry)
  • Chiropractors
  • Physical therapists
  • Occupational therapists
  • Clinical psychologists
  • Osteopathic practitioners
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Qualified speech-language pathologists
  • Qualified audiologists
  • Registered dietitians or nutrition professionals

MIPS Data Submission Methods

Eligible physicians can report data to CMS as individuals, a group, or a virtual group.

Eligibility Check for MIPS 2020 Participation as Individuals

For MIPS participation as individuals, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Surpass the Low-Volume Threshold requirements
  • Not qualify for Alternative Payment Model Participant

Eligibility Check for MIPS 2020 Participation as Group

For MIPS participation as a group, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Belong to a medical practice that surpasses the Low-Volume Threshold requirements
  • Not qualify for Alternative Payment Model Participant

The MIPS score and payment adjustment will be awarded as a group in this case.

 

Eligibility Check for MIPS 2020 Participation as Virtual Group

For MIPS participation as a virtual group, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Not qualify for Alternative Payment Model Participant
  • Be associated with a medical practice that surpasses the Low-Volume Threshold requirements & is part of virtual practice

 

The above-mentioned are all the requirements that a MIPS participant should know beforehand the MIPS data submission. We are halfway through QPP MIPS 2020, and many professionals already had planned and implemented a strategy for optimized performance in the end.

 

How to Report MIPS Data?

Physicians have a lot on their plate already, and the pandemic has increased their burden. In such a situation, MIPS quality reporting seems like a challenging task.

If you’re an eligible MIPS clinician, the best advice to you is to concentrate on quality care outcomes. A professional MIPS Qualified Registry will take your efforts into account, and you can target more measures if you have a proper plan of action on board.

Best of luck.

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QPP MIPS 2020, MIPS 2020, MIPS Qualified Registries, MIPS and Macra, CMS announces, Medicare Quality Reporting, coronavirus pandemic, healthcare industry

CMS announces QPP MIPS reporting Relaxations for 2020

The last few months have been tough for the healthcare industry. All stakeholders were trying desperately to assist each other and save resources for COVID-19 response.  Of course, meanwhile, CMS also took necessary measures to unburden some of the clinicians’ load.

Where physicians have already burned out with COVID -19 cases, the administrative burden of QPP MIPS 2020 was additional pressure. The dynamics have changed. The contact points that were easily accessible before are now operational via online mediums.

Thus, eligible clinicians and MIPS Qualified Registries can take benefit from it and serve effortlessly to the patients.

At first, CMS requested clinicians to impede elective medical procedures. In simple terms, it means to delay diagnostic procedures or treatments that don’t qualify for emergency conditions.

However, the process of offering flexibilities continues for the QPP MIPS. At first, CMS asked healthcare professionals to delay elective medical procedures and treatments, but with things starting to get back to normal, the Trump administration reopens all medical practices.

Telehealth was another option that was promoted to continue the services along with COVID response. QPP MIPS 2020 is also going to reward physicians who adopted telehealth and practiced it to accommodate patients from every corner. It not only accounts for improvement activities but for promoting interoperability.  It is a great opportunity for scoring high and target incentives.

The following are the relaxation areas that MIPS eligible clinicians can enjoy.

Relaxations for the QPP MIPS 2020

CMS states that the eligible clinicians who are significantly impacted by the public health emergency can apply for Extreme and Uncontrollable Circumstances to reweight any of the four or all MIPS performance categories.

However, they are required to submit a solid explanation for the impact on their medical practice.

A COVID-19 clinical Improvement Activity under MIPS is also introduced by the CMS.  Eligible clinicians can obtain outcomes via:

  • Participating in a COVID-19 clinical trial Improvement Activity and submit data into a data platform
  • Participating in the healthcare of COVID-19 infectees and submit patients’ data to Clinical Data Registry for research

As physicians are busy battling against coronavirus pandemic, CMS has decided to not use data reflecting from January 1st to June 30th, 2020 for the Medicare Quality Reporting and value-based purchased programs. These measures are taken to give advantage to eligible physicians to some extent as to minimize the administrative burden incurred during data collection and management. A lot of time and investment can be saved, henceforth.