2020 Pre-submission MIPS Point Round-up
Before we close out the 2020 MIPS reporting year, it’s important to ensure you’re taking advantage of every opportunity for higher pay-for-performance incentives, especially when the COVID-19 pandemic has had such an impact on revenue. Here are 3 topics to review before 2020 MIPS reporting wraps up and data is finalized for submission:
Eligibility and the Low Volume Threshold (LVT):
CMS will finalize MIPS eligibility in December to include data from the 2nd eligibility window. It is critical to understand the make-up of your practice’s MIPS eligible clinicians. Here are a few eligibility factors that may require action items to ensure you are maximizing incentives you will see in the 2022 payment year:
- If you are reporting as a group, make sure to report on data for all providers billing under your TIN, regardless of whether they bill Medicare or not. MIPS is an all-payer program so all provider data is required to be reported on when reporting as a group
- If your practice will report individually, make sure you are keyed into which clinicians are finalized as opt-in eligible. For the opt-in eligible clinicians, it’s important to keep in mind that you may only want to opt-in those clinicians that have higher expected MIPS scores, especially above the 85-point exceptional performance threshold.
High Priority/Outcome Measure Bonus Point Maximization:
It’s widely known that CMS scores the top 6 measures based on performance in comparison to benchmarks and that at least 1 of the 6 measures must be an outcome, or a high priority measure in lieu of an outcome measure. It is also widely known that outcome and high priority measures beyond the minimum requirement result in bonus points that are factored into your total quality score. What is often a surprise to practices and clinicians is the fact that they can report on more than 6 measures, which will ensure that even if a practice’s additional outcome or high priority measures don’t fall into the top 6 scored measures, they still count as additional outcome or high priority bonus points, which are added to the total quality score.
Measure Selection Limitations:
Measure selection is a big topic so let’s focus in on one important element that should be investigated as we near the end of the reporting period. Some specialties are limited in the selection of measures to choose from that offer the possibility of scoring the full 10 points. This is due to several reasons including a lack of new measures being created for some specialties, which forces practices and clinicians to report on measures capped at 7 points or worth only 3 points because they are missing a benchmark history. When faced with a true “glass half full” situation, it can be helpful to consider adding measures that may not fall directly under your specific medical specialty but which you have done the quality actions for and therefore could get performance points for. An example could be an OB/GYN reporting on the Advance Care Planning measure, which is also considered a high priority measure and will therefore result in additional bonus points. Even adding these extracurricular activity measures on later in the year is ok because you can update your standard processes and be ready to make these new clinical actions standard in the new year.
Make sure you have dedicated people ensuring you are maximizing points as we get closer to the end of the performance year. 2021 is the last year of the exceptional performance bonus as it was only planned for the first 5 years of the MIPS program. 2020 and 2021 are the most critical years to ensure you are maximizing your MIPS point earnings; not only because you will be rewarded with higher incentives in the 2022 and 2023 payment years but also because the 2022 reporting year will use historical scores to determine incentive and penalty thresholds. It is best to be ready to meet and exceed whatever point threshold will keep you out of penalty range and well into incentive range when the 2024 payment year hits.