The Merit-based Incentive Payment System (MIPS) is one of two tracks offered by CMS to meet the requirements of the Quality Payment Program (QPP). MIPS is a single program that replaces PQRS, EHR Incentive Program (Meaningful Use) and the Value-Based Modifier. Practices will earn a payment adjustment based on four performance categories: Quality, Improvement Activities, Promoting Interoperability and Cost. Each component is a weighted score that will contribute to the overall payment adjustment in 2022 for participation in the 2020 QPP program year.
Eligible clinicians who provide clinical care and bill under Medicare Part B FFS (Fee-For-Service) can participate in MIPS through the QCDR. MIPS-eligible clinicians include but are not limited to physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists. Clinicians can enter their 10-digit National Provider Identifier (NPI) number on the CMS website to view their QPP participation status by performance year.
The registries are an approved single QCDR reporting option for MIPS 2020. A QCDR is defined as a CMS-approved entity that has successfully completed a rigorous qualification process to collect medical and/or clinical data for the purpose of patient and disease tracking to foster quality improvement for patients.
Eligible clinicians who are actively submitting their patient data to the registries can request that we report their 2020 MIPS data on their behalf. To initiate this, clinicians must complete an electronic data release consent form (eDRCF). The eDRCF provides consent required by CMS that allows the QCDR to release data to CMS on the clinicians’ or groups’ behalf. Only data for eligible clinicians will be submitted to CMS if the eligible provider and/or group completes an eDRCF by the specified deadline.
Providers must complete the following three steps before 2020 MIPS data can be submitted by the PINNACLE and Diabetes Collaborative QCDR:
For more information, existing registry participants should contact their dedicated client account manager or the NCDR participant support team at email@example.com or 1-800-257-4737.
Yes, a practice may request that the QCDR submit MIPS data on behalf of all clinicians in the practice. If a practice is reporting its clinicians as individuals, each individual provider must complete his/her own eDRCF for MIPS data submission. All clinicians at a given practice are not required to participate in the QCDR for MIPS reporting.
Clinicians who are reporting MIPS data through another CMS program such as the Medicare Shared Savings Program are not eligible to submit MIPS data via the PINNACLE and Diabetes Collaborative QCDR.
Please note, some groups may have clinicians participating under a Next Generation ACO Model who may be required to report MIPS. In that case, those affected clinicians are eligible request that the PINNACLE and the Diabetes Collaborative QCDR submit MIPS data on their behalf.
In 2020, practices of two or more eligible clinicians can participate as a group practice. Group practice level reporting (GPRO) is when performance data for all clinicians in the practice is aggregated at the Tax Identification Number (TIN) level. All clinicians under the TIN will receive the same score. Solo practitioners are not eligible to report as a group.
GPRO reporting may make it easier for providers to meet MIPS reporting requirements. If the entire practice meets the requirements, CMS considers all clinicians in the practice to be participating in MIPS successfully. For example, a practice with two eligible providers can meet the requirements if the first provider reports 40 percent of his or her patients and the second provider reports 60 percent of his or her patients.
The PINNACLE and the Diabetes Collaborative QCDR can accommodate GPRO reporting. Practices should notify their dedicated FIGmd Client Account Manager of their desire for GPRO reporting ahead of the CMS deadline.
The reporting requirements for GPRO are the same as those for individual reporting. Group practices must submit six quality measures, including one outcome measure or one high-priority measure and report for at least 70 percent of the group practice’s patients. In order to successfully report data for Improvement Activities, at least 50% of the providers within the group must participate in that activity during any continuous 90-day period in the performance year.
Simply reach out to your dedicated FIGmd client account manager to inform them your practice is reporting as a group for 2020.
Note: for group practice reporting, you only need to complete one eDRCF per TIN.
If a provider or group elects to submit data to CMS using the PINNACLE or the Diabetes Collaborative QCDR, Veradigm will provide CMS with quality measures, improvement activities and promoting interoperability measures selected by the practice as long as they meet each performance category requirement. Practices will select their own measures and activities for submission via the Physician Dashboard.
Patient encounters that occurred between Jan. 1, 2020 and Dec. 31, 2020. Eligible clinicians and groups are required to report a full year of quality data in 2020.
Practices are required to submit 100 percent of patient encounters that meet inclusion criteria. Generally, that includes face-to-face office visits for patients with coronary artery disease, heart failure, hypertension, diabetes and/or atrial fibrillation.
No, participation in registry data collection requires providers and practices to submit all data elements on all patients that meet the inclusion criteria, regardless of payer status, not just the select MIPS measures.
A clinician or practice may submit for MIPS through multiple methods, if they do not plan to submit Quality using the CMS Web Interface as a group practice or are required to use the CMS Web Interface as a participant in an Accountable Care Organization (ACO). Each reporting mechanism must encompass a complete reporting period and must include the minimum reporting requirements. Please note, only one submission method can be used to report the Promoting Interoperability performance category.
No, CMS does not allow the combining of incomplete submissions to meet the MIPS requirements.
Yes, eligible clinicians and groups will select their own measures and activities for submission. If you decide to report using the PINNACLE or the Diabetes Collaborative QCDR, there are several available resources to review your performance, including monthly feedback performance reports that detail adherence to clinical measures across all patient encounters that meet inclusion criteria. talk to your FIGmd client account manager to help you use the physician dashboard to gauge performance.
We have also provided a crosswalk of MIPS measures with the standard registry measures, where applicable. You can also review your performance at the group or individual provider level via the Physician Dashboard. If you have questions regarding your measure performance, contact your FIGmd client account manager immediately.
NOTE: Regular monitoring of your data via the physician dashboard is required. Practices can use to use the monthly performance reports to gauge their likelihood of meeting 2020 MIPS requirements. Practices also can use the MIPS Dashboard within the Physician Dashboard to gauge their performance in each performance category and review their preliminary scores.
CMS is responsible for all payment and adjustment determinations. Neither Veradigm nor the ACC can guarantee performance outcomes.
Clinicians and practices will receive their feedback and scores by logging into the CMS QPP Portal using their HARP account credentials.