Remember 2019? It already seems so long ago. But for physicians participating in the Medicare Quality Payment Program’s (QPP) Merit-based Incentive Payment System (MIPS), there is one more 2019 task still to complete: submitting data for that calendar year.

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Congratulations are in order for physicians following the AMA’s 10-step 2019 MIPS Action Plan. You have arrived at step 10. By this time, physicians must understand whether they are submitting as an individual or with a group and know which categories they are reporting on and the mechanism being used.

With one notable exception, all submissions are due to the Centers for Medicare & Medicaid Services (CMS) by March 31, 2020. This applies for physicians using the CMS Web Interface. The deadline for accountable care organizations, pre-registered groups and virtual groups is also March 31.

However, for physicians using the claims-reporting option, quality measures reported via Medicare Part B claims have been submitted throughout the 2019 performance period, and physicians can sign in to for preliminary feedback.

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For practices submitting 2019 Medicare Part B claims with quality data codes, the last day for reporting is determined by their Medicare Administrative Contractor (MAC), according to a CMS fact sheet. But claims must be processed no later than 60 days after the close of the 2019 performance period. The CMS advises practices to check with their MAC for guidance.

Medicare Part B claims can only be used for submitting measures in the Quality performance category.

Physicians are encouraged to check the QPP website for more precise reporting deadlines.

The AMA also offers these tips:

  • If using a vendor, make sure they are prepared to meet the deadline. Don’t leave it to chance.
  • Verify and validate data prior to submission.
  • If data is being submitted by a Qualified Clinical Data Registry, make sure all necessary changes are done before March 31.

CMS has responded to physician feedback and has made improvements to its reporting systems.

“CMS has added significant capability to its data submission site since Year 1 of the QPP in 2017,” the MIPS Action Plan states. “The site allows you to see performance data for each measure, your predicted score, and certain missing or incomplete information. If you submit data via claims or through the CMS Web Interface, it will allow you to see beneficiary-level information about data completion and performance for each measure you report.”

No-cost support and technical assistance is available for small, rural or underserved-area practices from CMS. The AMA also has resources designed to help small practices succeed.

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Physicians and small practices that fall below thresholds for required QPP participation may opt into the program this year if they believe their performance will earn them a quality bonus. But practices are warned that, if they decide to opt in based on their 2019 performance, they will not be allowed to pull out of the program for the 2019 performance year.

Physicians with QPP questions are encouraged to call CMS at (866) 288-8292, Monday–Friday, 8 a.m.–8 p.m. Eastern time, or to send an email to [email protected]

The move from traditional fee-for-service care models to new payment and delivery models dictates that physicians reevaluate how quality measures and payments are linked to outcomes. The AMA has the tools to help adapt care delivery models to improve quality and reduce practice costs.

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