The moment of truth is drawing near. According to CMS, the first MIPS performance feedback reports will be available shortly in July. These performance feedback reports based on 2017 MIPS submissions will provide the final MIPS score and the MIPS payment adjustment for the eligible clinicians that will be applied to the allowed Medicare charges beginning Jan 1, 2019.
There are a few things you need to know to get ready to timely review your feedback report so you have plenty of time to get the performance reassessed by requesting a Targeted Review in case you find a discrepancy in the report.
Performance Feedback Reports are Accessible Only Via the QPP Portal
The MIPS performance feedback reports will not be mailed to the providers or provider organizations. To access the report, the designated staff or an authorized entity will need to login to the QPP portal using their EIDM Account. Ensure that you have an EIDM account and can log in to it successfully, especially if you used Claims for submitting 2017. If you have not updated your password in last 60 days, you might need to reset your password so you can access your reports as soon as they become available.
When the performance feedback report is available, take the following steps 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 Harvey, Irma, Maria, the 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 2017, 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, 2018.
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 2019 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
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 2017 and is therefore ineligible for receiving payment adjustment in 2019. 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 an Interim guide about the Targeted Review by CMS for additional details. An updated guide will be available in the QPP resource center when the 2017 performance review reports become available.
How to Monitor and Improve 2018 Performance?
You soon will have the 2017 performance reports. You can definitely glean some insights from it and leverage them to make the improvements for the 2018 performance year. While you do that, you must not lose sight of certain facts.
- 2017 was the introductory year for MIPS and offered test pace option, but MIPS has picked up pace since then. Even though the volume thresholds went up ($90,000 in allowed Medicare charges AND 200 patients), the requirements and the performance thresholds have gone up too (from 3 points to 15 points).
- Medicare Drug charges are no longer included in determination of the volume threshold or application of payment adjustment.
- Quality measure benchmarks have changed, and will change every year for every submission method (Claims, Registry, EHR) based on the new data submitted.
- New bonus opportunities and flexibilities were introduced for the Promoting Interoperability (formerly ACI) performance category.
- New Improvement Activities were added for 2018
- Small Practice Bonus, Complex Patient Bonus, and Performance Improvement Scoring for Quality category were added
As you can see, the MIPS landscape in 2018 looks quite different than it did in 2017. So the 2017 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 is up-to-date with all the changes for 2018 performance year. It takes care of all the MACRA rules so you can focus on what you can control.
Download a sample report from one of our partners to get an idea of how performance monitoring can help you identify the best measures for your practice, significantly improve your scores and align your efforts in multiple areas of care delivery.