Payment & Delivery Models

Answers for your MIPS data-collection head scratchers

Physicians participating in the new Medicare Quality Payment Program (QPP) do not have to build new data-collection processes from scratch. Opportunities exist to facilitate Medicare Incentive-based Payment System (MIPS) reporting by using processes already developed for the Physician Quality Reporting System (PQRS) and other legacy programs.

To help physicians on their journey into value-based payment systems, the AMA has developed “Deep Dive FAQ” documents for data mapping and hospital-employed physicians that supplement the AMA’s previously released 10-step MIPS Action Plan and other related documents.

The data-mapping document features answers to 35 frequently asked questions and offers strategic recommendations for the transition to Medicare’s new value-based payment system.

This includes information on how to leverage a practice’s prior experience with PQRS, Meaningful Use and Value-Based Modifier programs by using the Centers for Medicare & Medicaid Services’ (CMS) Quality Resource Utilization Report (QRUR) to see how CMS may measure its performance on MIPS quality and cost measures.

Registries have more measure choice

The AMA FAQ provides instructions on accessing a QRUR report, explanations of the useful information it contains (such as how to use its data to qualify for MIPS Improvement Activity points), and guidance on whether to report to MIPS as an individual or part of a group.

Information is provided on the different specifications for reporting measures either by using claims, reporting as a group, or via an electronic health record (EHR) or Qualified Clinical Data Registry (QCDR). For example, physicians using a QCDR can better customize their reporting by submitting data on measures that are not included in the nearly 300 quality measures listed in MIPS that have been dubbed “non-MIPS measures.”

“Despite the name, these measures will in fact be scored under the MIPS,” states the answer to question No. 9. “This may be advantageous, particularly if a non-MIPS measure enables you to submit performance information about your practice that demonstrates high quality care.”

The answer to question No. 19 directs readers to where they can find information about QCDRs on the CMS website and explains why it may be advantageous to look it up.

“This is because QCDRs have the unique ability to submit data on non-CMS quality measures developed by third parties (including specialty societies),” the answer states. “As such, a QCDR may help you submit the data that are most relevant to your practice.”

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Guidance is also given on special data-reporting considerations for physicians in alternative payment models (APMs), Medicare Shared Savings Program accountable care organizations and MIPS APMs.

Information on MIPS performance will be publicly posted on the CMS Physician Compare website, so it’s important for clinicians to review their data before it goes online. Physicians have 30 days to review and possibly contest what CMS will post. CMS is expected to release additional information about this process and updates will be posted on it QPP website.

“Specifically, CMS will report clinicians’ names, performance under each MIPS category, the names of clinicians in advanced alternative payment models (and potentially the names and performance data for the advanced APMs), and aggregate information for all eligible clinicians under MIPS,” the answer to question No. 26 states.

What vendor contracts must include

Other third-party reporting options are available, and recommendations are offered for what services to request in a vendor contract.

Physicians should insist that their vendors provide internal performance-tracking data. While the government does not require vendors to offer this service, the answer to question No. 20 notes that this function helps physicians assess their MIPS performance during the year. This can be helpful to physicians in deciding whether to change which measures they will report while also assisting in the overall management of care quality.

A similar service some vendors may offer involves providing “snapshot” data on MIPS performance, which the answer to question No. 30 notes can be helpful. It is also recommended that a process be established to validate that data is being transmitted correctly.

The document also answers questions on the types of protections physicians should build into their vendor contracts. It’s recommended that this include having the vendor take responsibility “for the bulk” of data submissions to CMS and for protecting patient privacy.

“You should ask for indemnification against any costs you incur as a result of the vendor’s actions—this should include any negative payment adjustments as well as any compliance claims associated with attestations provided on behalf of your practice,” states the answer to question No. 32.

All contracts should include a business associate agreement stipulating that the vendor will comply with the Health Insurance Portability and Accountability Act and ensure that patient information is protected, according to the answer to question No. 34.

The FAQ document can help physicians assess what might be their most important practice-management task at this stage of the QPP process: Verification that they are on the right track for their intended level of MIPS reporting—either minimum, partial or full.

If physicians are falling behind in full or partial data reporting, they may need to consider doing the minimum, and that means participating in the “one patient, one measure, no penalty” option to avoid a 4 percent negative Medicare payment adjustment for 2019.

Other tools physicians may find particularly useful include the CMS MIPS Participation Status checker that verifies if a provider is exempt from MIPS reporting and the AMA Payment Model Evaluator, which helps physicians better understand the financial impact QPP may have on their practices.

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