A new policy was established in the 2019 Physician Fee Schedule (PFS) Final Rule that authorizes CMS to make changes to the MIPS Quality category scoring methodology for any measure(s) that may be significantly impacted by clinical guideline changes or other changes as CMS sees fit. The intent of this policy is to hold harmless any reporting practices and clinicians who submit data on measures that become suppressed due to a clinical guideline or other CMS approved change. This policy change has been executed due to the clinical guideline changes for four 2019 measures:
- Measure 69 – Hematology: Multiple Myeloma: Treatment with Bisphosphonates (MIPS CQM)
- Measure 110 – Preventive Care and Screening: Influenza Immunization (Medicare Part B Claims, MIPS CQM, eCQM, CMS Web-Interface)
- MIPS 134 (CMS2v8) – Preventive Care and Screening: Screening for Depression and Follow-Up Plan (eCQM)
- Measure 450 – Trastuzumab Received By Patients With AJCC Stage I (T1c) – III And HER2 Positive Breast Cancer Receiving Adjuvant Chemotherapy (MIPS CQM)
The resulting impact to the MIPS Quality category scoring will be an overall denominator reduction by 10 points if data is submitted on any of the suppressed measures.
CMS knows that, for example, several practices and clinicians reporting on measures like Measure 110 – Influenza Immunization, typically score higher on the measure and their MIPS Quality scoring would therefore be greatly impacted if the benchmarking was simply removed and the practice/clinician was given a score of just three points. The new CMS policy and methodology for handling this difficult scenario is a generous one especially when practices have reported and submitted beyond the minimum requirements of the MIPS Quality category.
Outside of any measure suppression, an average practice is scored on their top 6 quality measures, each of which is worth a possible 10-points, resulting in a 60-point denominator. For example, a practice that achieved 9 points on each of the top 6 scored measures would receive 54/60 ((6 measures x 9 points each)/60-point denominator), resulting in a score of 90%, which when applied to the practice/clinician’s MIPS Quality category weighting determines the MIPS Quality category Composite Performance Score (CPS). If their MIPS Quality category weight is out of 45, the math works out as 90% of 45 equaling a total of 40.5 MIPS Quality CPS points.
The suppression policy enacted with the 2019 PFS final rule allows CMS to reduce the denominator by 10 points for each of the suppressed measures that were reported on. If the practice/clinician in the above example had reported measure 110 as one of their measures but also reported on more than just 6 measures and had scored 9 points on all measures, the following scoring would be applied: 6 measures x 9 points/50-point denominator (54/50 = 100% (cannot exceed 100%)). The practice would receive 100% of their MIPS Quality category weight of 45, meaning full credit achievement for the category.
MIPS is a complicated game of strategy with the best of intentions to improve the quality and cost of care for patients. In order to succeed in this endeavor, MIPS demands insight and expertise to handle all possible scenarios and reporting surprises. To achieve optimized reporting and maximum rewards, the MIPS program requires an analytics application to manage gaps in care and a dedicated team committed to your success.
Value-based care analytics extends far beyond data aggregation and reporting. Success in value-based healthcare depends on strong clinical data expertise, deep programmatic knowledge and performance analytic solutions that are flexible and transparent.
We partner within each level of an organization to help you make the transition to value-based risk smoothly, with less administrative burden and no disruption to the delivery of care.
ReportingMD has more then 17-years’ experience in this category and is uniquely positioned to create a value-based care analytic management program that allows:
- Optimized quality scores
- Reduce physician, IT and administrative burden
- Enhance performance incentives and reimbursement
- Improve patient outcomes through care-gap management
Think of our team as your “plug-and-play” quality analytics department.