The moment of truth is here. The Performance Feedback Reports for MIPS 2018 became available earlier in July. In our last blog, we discussed how can you access these reports and how you can go through the report to see your final MIPS score and the MIPS payment adjustment that will be applied to the allowed Medicare charges for eligible clinicians beginning Jan 1, 2020.
In this blog, we will focus on the things you need to know to timely review your feedback report and request a Targeted Review in case you find a discrepancy in the report.
Ensure Accuracy of Data Included in the Performance Feedback Report
Performance Feedback Reports are accessible only via the QPP portal by logging in to your HARP account (previously EIDM). The following steps will help you to ensure accuracy of your performance feedback report:
Tally that the performance scores for each performance category is same or close to the score that you had estimated before submission. If you find any discrepancy in the performance category score, it could be due to data quality issues, calculation errors, or due to a discrepancy in the automatic re-weighting of performance category weights.
Check that the clinician eligibility for individual or group reporting has been assessed accurately and payment adjustment assigned accordingly
If clinicians in your practice were subject to extreme and uncontrollable circumstances (hurricanes, wildfires, or other natural disasters), verify that the performance categories have been re-weighted accordingly, and that no negative payment adjustment is applicable, especially for the clinicians who reported as individuals.
If you were an eligible MIPS-APM participant, or Partial QP opting to participate in MIPS in 2018, ensure that you were scored according to the APM scoring standard.
If you find any error in any of the above-mentioned areas, and you have supporting documentation to prove it, you must submit your request for a Targeted Review by September 30, 2019.
What is MIPS Score Targeted Review and How to Request it?
A targeted review is a process through which eligible clinicians can request CMS to review the calculation of their 2020 MIPS payment adjustment factor and the additional payment adjustment factor for exceptional performance (MIPS score of 70 or higher).
REQUESTING TARGETED REVIEW
This review can be requested by MIPS eligible clinicians being scored under either the MIPS scoring standard or the APM scoring standard.
The eligible clinicians, designated support staff, and the authorized third-party intermediaries (Qualified Registries, Health IT vendors, and QCDRs) can request the targeted review. This review must be requested at the same level (individual or group) at which the data for MIPS was submitted to CMS.
Once a Targeted Review is submitted, CMS might request the supporting documentation. These documents must be submitted to CMS within 30 calendar days of initial request. Few examples of supporting documentation are:
Supporting extracts from the MIPS eligible clinician’s EHR for the data accuracy
Copies of performance data provided to a third-party intermediary by the clinician or group
Copies of performance data submitted to CMS
Signed contracts or agreements between a clinician/group and a third-party intermediary
APM participation agreements
Partial QP election forms
QPP Service Center ticket numbers
THE BOOK OF EVIDENCE
As you can see, the requirements for requesting a Targeted Review are very similar to the documentation you need to provide if you receive a MIPS Audit request. So, creating the Book of Evidence has two-fold benefit.
It helps you evaluate your Performance Feedback Report and catch any discrepancies in performance category score, or the composite MIPS score.
It serves as your evidence book for each MIPS performance year in case of an audit.
REQUEST FOR REVIEW DENIED
Request for a targeted review may be denied if duplicate requests are submitted by a practice or the request is NOT related to the calculation of MIPS payment adjustment factor and the additional adjustment factor for the exceptional performance.
If a request for targeted review is denied, the MIPS final score and the associated payment adjustment will stay unchanged.
REQUEST FOR REVIEW APPROVED
If a request for targeted review is approved, the outcome of the review will vary based on the request, and the supporting documentation provided. It is important to understand that the review could also result in an unexpected outcome. For instance, it could be found that a clinician who requested a review for a calculation error must’ve been excluded from MIPS in 2018 and is therefore ineligible for receiving payment adjustment in 2020. Similarly, unfavorable performance category weight redistribution could also happen as a result of the review.
The outcome of the review will be communicated via email to the submitter. The specific changes to the performance category scores, the final MIPS score, and the associated payment adjustment will be updated based on the review. The updated performance feedback report will be available on the QPP portal.
You can refer to the 2018 Targeted Review User Guide by CMS for additional details.
How to Monitor and Improve 2019 Performance?
The 2018 performance reports can help you glean some insights and leverage them to make the improvements for the 2019 performance year. While you do that, you will also need to consider the fact that there have been some key changes in 2019 MIPS requirements.
MIPS requirements have gotten significantly harder since 2018. The performance threshold has increased to 30 points (from 15 points in 2018) and the additional performance threshold is now 75 points.
The performance category weights have been adjusted: Quality-45, Cost -15, PI-25, IA-15
For Quality category, multiple collection types can be combined to submit data for 6 quality measures. The benchmarks have been revised for all collection types based on latest data.
The Promoting Interoperability category has been completely restructured.
Some new Improvement Activities were added and some were removed for 2019
Small Practice Bonus has been moved to Quality category. Some other bonus points have been removed.
New measures have been added for the Cost category.
As you can see, the MIPS landscape in 2019 looks quite different than it did in 2018. So the 2018 performance report could only give you a general direction, but not the specifics, as they have changed. It's hard to know the current picture without regular monitoring, and without knowing the exact picture, it is impossible to make course corrections. That is where MyMipsScore can help. MyMipsScore app is up-to-date with all the changes for 2019 performance year. It is available to provider organizations, MIPS consultants and vendors as a subscription service. Alternatively, our MIPS consulting services can help providers to monitor their performance, identify the best measures for your practice, and significantly improve your scores.