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MIPS Reporting During the Pandemic

We are currently experiencing a once-in-a-century pandemic that has turned our usual way of life on its head. MIPS reporting has fallen to the wayside of saving lives and maintaining sanity as we work to adjust to a new normal. Practices should understand their options and what could still be earned by MIPS reporting in 2020.

Fortunately, CMS has been understanding of the MIPS reporting and submission impact on practices due to the public health emergency (PHE) and has released information and an extreme and uncontrollable circumstances exception application to help ease the burden of reporting.  However, do not be scared away from 2020 reporting just because CMS is providing an “out”.  With fewer practices reporting, fewer practices will share in the exceptional performance bonus pot, which is exempt from the budget-neutral regulation. There are several ways to potentially earn quite a high-performance adjustment (up to 6.25% of your Medicare allowable charges). It is critical to note that you must submit for a minimum of two performance categories under MIPS in order to get scored and adjusted for the 2020 reporting year.

For the Quality performance category, telehealth will have a potentially large impact on measure selection.  Choose measures with a larger number of eligible events and make sure to secure an easily accessible patient portal. Few practitioners paid attention to the telehealth modifier prior 2020 as telehealth was an underutilized tool of the medical profession. As social distancing and lock downs progressed, practices found that telemedicine was the solution to the sudden problem of in-patient visits and possible COVID-19 transmissions. Some quality measures have telehealth modifier restrictions (even exclusions) making it critically important to review measure specifications to see whether or not telehealth modifiers are a factor. If telehealth modifiers are excluded from the measure, your practice may have difficulty getting enough eligible events to report the measure and score beyond the base of 3 points. If your practice had a measure in 2019 with fewer than 40 or so eligible events, it may fall short of the needed 20 events due in part to the lack of visits as well as telehealth modifiers.

Regarding the Improvement Activities performance category, use the processes already in place within the practice, when possible. Review the activities list to see if any standard operating procedures or activities internally tracked by your practice could count as an improvement activity. For instance, if your practice already has extended hours, that can be used as an Activity.  Just make sure that at least 50% of all eligible clinicians participate in the improvement activity for 90 consecutive days prior to the end of the year. A new IA was added in May, which related to COVID-19 clinical trials.  If 50% or more of your clinicians are participating in a COVID-29 clinical trial, your practice should take advantage of this new high weighted improvement activity.

For the Promoting Interoperability (PI) performance category, practices and clinicians should consider taking advantage of the hardship application options. The benefit to completing a PI hardship application is that practices and clinicians can still submit for the category and be scored, if at the end of the year, they realize their PI score would actually be better than if the points were reweighted to the quality category due to a hardship exception.

By reviewing the measures and activities, and options during the pandemic, you may be able to not just report for MIPS 2020, but report exceptional performance, reaping the benefits of a 6% or more adjustment. ReportingMD is here to assist with that performance enhancement by providing experience, knowledge and technology to get you there.

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.

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