On June 18, 2019, the AUA hosted a webinar featuring Dr. Barbara Connors and Patrick Hamilton, Merit-Based Incentive Payment System (MIPS) experts from the Centers for Medicare & Medicaid Services (CMS), who explained various aspects of the MIPS programs and answered questions.
Topics covered during the webinar include:
- Year 3 Requirements of MIPS (Quality, Improvement Activities, Promoting Interoperability, and Cost)
- 2017 Quality Payment Program Experience Reports
- Interoperability and Patient Access Proposed Rule
- CMS Innovation Center
- Patients over Paperwork
- Extensive Question and Answer Session
Contact Quality@auanet.org or 410-689-3925 with questions
Transcript from Question & Answer Session
1. For Promoting Interoperability, if a practice has an exemption on Direct Messaging - send and receive, how will the performance be added to Quality? There is not clear explanation.
Direct Messaging was a Promoting Interoperability requirement in 2018, but it was not carried over to 2019. So, we assume that you mean Health Information Exchange. If you are exempted from one of the Promoting Interoperability measures in 2019, the points are reweighted to other Promoting Interoperability measures. This is different than previous years where if you did not have a score for one Promoting Interoperability measure, you failed the entire category. In 2019, if you don’t get points for any one measure, you can still get points for the others. There are 100 points available in Promoting Interoperability, and the category is worth 25 points. If you get 100 percent of the 100 points, you’ll get the whole 25 points for the category score. If you get 80 percent, you get 20 points. So, you are still able to get points for Promoting Interoperability. That wasn’t the case for Meaningful Use where if you didn’t meet the threshold for one measure, you failed regardless of how you scored on the other measures. The category has been restructured. However, CMS wouldn’t say to anyone you should settle for zero points. Instead a participant should see if there are any measures in the category that you can do. We believe in the upcoming notice of proposed rule making, CMS will propose a way to reweight points for the individual measures in PI, which is different than reweighting the entire category to Quality.
2. You can claim an exemption for Promoting Interoperability, but they also say you only need to submit one case in order to qualify. There isn’t a minimum threshold like there is in Quality where you need to have 20 cases in order to submit. So, if you only have a few cases, is it better to claim an exemption versus to report?
If in your case you have fewer than 20 Medicare beneficiaries, you should first use the look-up tool to determine whether you are exempt from participating. That said, it depends on how you would fare. If you think you would do better having a higher Quality score by upping your Quality score to 70 percent of your final score by not reporting for Promoting Interoperability, that is probably where the decision would lie.
3. If I choose to opt-in, do I have to let CMS know or do I just report?
On the QPP website, in the MIPS section you can access the Reporting Options Overview. In that section there is a link to register to opt in. CMS will know if you are exempt through those criteria we talked about. If you are exempt and you just submit your data but you don’t register, we’ll think that you are voluntarily reporting. You will get a feedback report and you will know what your score is, but you won’t be subject to any of those adjustments (upward or downward). Keep in mind there are two options: one is to voluntarily participate where you will receive a feedback report but you won’t receive a change in your payment either up or down. If you opt-in, you are subject to the payment adjustment. So, there is an either/or.
4. For the Promoting Interoperability Public Health and Clinical Data Exchange measure, where can we find which registries accept data from ambulatory providers as well as which registries are qualified to meet the measure.
I believe that is all listed under the measure specifications available on CMS’s QPP website. You can go in and access not only the actual QPP portal but there is also a resource page where you can go and pull up all the specifics. That is the devil in the details. [Patrick later provided a link available through HealthIT.gov].
5. Does it matter which version of CEHRT you use for Improvement Activities?
Starting in 2019, only the 2015 version of CEHRT can be used, and that’s across all programs. So, that is for the entirety of MIPS. That is also for Medicaid Promoting Interoperability and Hospital Promoting Interoperability as well as the models we are testing.
6. For improvement activities, do you include all patients or just Medicare patients?
This program for now is Medicare Part B. Now we are beginning to include the other plans. So, in future years it could potentially change, but for this year and previous years, it is Medicare Part B.
7. Can you submit through claims for improvement activities?
(Dr. Connors displayed the Improvement Activities portion of QPP.CMS.gov.) Improvement Activities is an attestation activity. The QPP website Resources section has materials for IA including the requirements for a small practice versus a larger practice, how we score, special status, if you are a patient-center medical home, how would you submit data, and how you would log in and attest to the improvement activities.
8. If a practice is not doing many opioid treatment plans, what will CMS require for audit purposes for presence of agreements in EMR? Are there examples of agreements that CMS can provide?
It is optional for the first year; so, we will not be doing anything in terms of auditing the opioid treatment agreements for 2019.
9. What is the score range for the all-cause hospital readmission measure? Is it 3-10 like other Quality measures?
We will have to look this up and provide the answer later. From the 2019 Final rule: “for the 2021 MIPS payment year, …apply a 3-point floor for each measure that can be reliably scored against a benchmark”…this includes all-cause hospital readmission.
10. Are there requirements for the security risk analysis?
There are 3 attestation questions that must be answered before you even submit your Promoting Interoperability measures, and the security risk analysis is one of those attestations. This is highlighted on slide 24.
11. Is it possible to participate in MIPS without an EHR?
If you choose to participate, you should apply for a PI hardship exemption if you meet any of the criteria below.
- You have insufficient internet connectivity
- You have extreme and uncontrollable circumstances, including:
- Practice Closure
- Severe Financial Distress (Bankruptcy or Debt Restructuring)
- Vendor Issues
- You don't have any control over whether CEHRT is available
- You're using decertified EHR technology
If you’re in a small practice, for Quality for example, you can continue to use claims. Cost you are not submitting anything anyway. For Improvement Activities, you can attest on the website. If you perform pretty well in those categories, you will probably well surpass those 30 points and get some kind of upward adjustment.
We suggest if you are a small practice to review the criteria, which again are on the QPP website under Promoting Interoperability/ Can I Apply for a PI Hardship Exception
12. Can I earn improvement points in every category?
No, for Quality and Cost only.
13. In terms of APMs, are there certain measures, etc. our practice should do to make the transition easier?
It’s a good question but models differ. I realize that it is not a direct or straight answer, but it would really depend on the kind of model a provider or practice wants to go into. As we develop models, we are trying to align those measures more closely to the MIPS reporting. In the end I think it is more important you are not choosing measures that are topped out. Another aspect to the reporting is, let’s say they report 9 measures instead of 6; we’ll automatically take the 6 measures in the Quality category that have the highest score assigned.
14. If I apply for a hardship exemption, what is the turnaround to know if it has been approved? In other words, if someone applies, how long will it take for someone to know if they have been approved?
For PY 2019, you can apply for either the Promoting Interoperability Hardship Exception or the Extreme and Uncontrollable Circumstances Exception. If want to know the status of your application once you have submitted it, go into the look up tool.