MACRA Minute September 2019

September 2019

Now Available: PI Hardship Exemptions

The 2019 QPP Exception Applications for the Promoting Interoperability performance category are now available. Applications must be submitted by December 31, 2019.

MIPS ECs, groups, and virtual groups may submit an application citing one of the following reasons:

  • You’re a small practice
  • You have decertified EHR technology
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of CEHRT (simply lacking CEHRT does not qualify you for re-weighting) Note: EC’s already exempt from PI need not apply

If you have questions about the hardship exceptions, please refer to the 2019 Exceptions: Frequently Asked Questions document.

Reminder: Upcoming Targeted Review Deadline

ECs that suspect an error was made to their 2020 payment calculation have until September 30 (before 7 p.m. CT) to submit a targeted review. The following are examples of circumstances warranting a targeted review:

  • Errors or data quality issues for the measures & activities you submitted
  • Eligibility & special status issues (e.g., you fall below the low-volume threshold & didn’t qualify for a payment adjustment)
  • Being erroneously excluded from the APM participation list & scoring standard
  • Performance categories not automatically reweighted due to extreme & uncontrollable circumstances

The request form can be found on the performance feedback page of the QPP Portal. After completing the review, you will receive a confirmation email or request for further documentation.

Once your review has been evaluated, you will receive an email that either approves or denies your request. Decisions are final & no further review will be available once the decision is made.

For More Information:
If you need assistance with a Targeted Review, please contact your Telligen QPP team at 1-844-358-4021 or the QPP Help Desk at 1-866-288-8292.

Additional information is available in the following CMS materials: Targeted Review Fact Sheet & Targeted Review FAQs.

ICMY: QPP 2020 Proposed Rule

In late July, CMS released proposed policies for the QPP 2020 performance year.

Key 2020 Proposals Include:

  • Increasing the performance threshold to 45 points (from 30 points)
  • Decreasing the Quality category weight to 40 percent (from 45 percent)
  • Increasing the Cost category weight to 20 percent (from 15 percent)
  • Increasing the completeness threshold for quality data submitted
  • Increasing the threshold for groups reporting an Improvement Activity 
  • Revising specifications for the Total Per Capita Cost & Medicare Spending Per Beneficiary Clinician Cost Measures
  • Updating requirements for Qualified Clinical Data Registry measures, including the services third-party intermediaries must provide (beginning performance period 2021)

The Future of MIPS

CMS is committed to the ongoing transformation of MIPS, including:

  • More streamlined & cohesive reporting
  • Enhanced & timely feedback loops
  • Pathways of integrated measures that are meaningful to clinicians & patients
  • Introducing the new MIPS Value Pathways to encourage the transition to APMs & promote value

Highlights of the MVP Proposals Include:

  • The creation of “bundles” or “tracks” of care called MVPs that connect measures and activities across the four MIPS performance categories
  • Incorporate a foundation leveraging Promoting Interoperability measures and administrative claims-based quality measures
  • Examples of MVPs include: Major Surgery and Diabetes Prevention and Treatment
  • Clinicians participate via one MVP, which includes measures and activities for the Quality, Improvement Activities, Cost and Promoting Interoperability performance categories
  • We envision that MVPs will be available for all clinicians and co-developed in partnership with specialty societies or other organizations

Submit Your Comments:
CMS is seeking comment on a variety of proposals, including the MVPs. They’re also seeking feedback on how to further transform MIPS to reduce burden, increase value, and focus participation around health priorities that are meaningful to practices and specialties.

Comments are due by September 27, 2019 & can be submitted electronically to or via regular, express, or overnight mail.

Learn More:
See the following CMS resources for more information: 2020 Proposed Rule Fact Sheet, & MIPS Value Pathways Diagrams.

Podcasts: Now Available from Telligen & CMS

Telligen 2020 Proposed Rule Podcasts

To learn more about the proposed changes for the Quality Payment Program in 2020, listen to our podcast series. Each episode highlights a section of the rule and how it will affect the program. Find all of the podcasts here.

  • Episode 1: General Changes Proposed for QPP in 2020
  • Episode 2: Proposed Changes for the Quality Category
  • Episode 3: Proposed Changes for the Improvement Activities and Promoting Interoperability Categories
  • Episode 4: Proposed Changes for the Cost Category

CMS Beyond the Policy Podcast
Episode 6: Dispatches from the Blue Button Developers Conference

The Blue Button Developers Conference brings together some of the nation’s top private-sector developers who help CMS better serve Medicare beneficiaries by leveraging Medicare claims data.

This podcast features key remarks from CMS Administrator, Seema Verma, application developers and Medicare beneficiaries. They share information regarding the launch of the pilot project, Data at the Point of Care and the value of these applications. Find the new episode here.

Register Now: CMS Webinars & Events

September 2019 LAN Webinar: APM Joining Considerations for Solo & Small Group Practices
This event will provide free and objective information on:

  1. What is required to participate in an advanced APM
  2. Advantages of transitioning from MIPS to an APM
  3. How to know if your practice is ready

The webinar will feature a panel of experts who:

  • Understand APMs
  • Work regularly with clinicians and practices to help them succeed in MIPS and APMs
  • Provide practical advice on APM participation, and whether it will benefit your practice and patients

Tuesday, September 17, 2019, 10:00 – 11:00 a.m. CST
Thursday, September 19, 2019 2:30 – 3:30 p.m. CST

October LAN Event: Transforming your Practice Workflow to Succeed in MIPS
At this roundtable event, panelists will share insights & challenges to succeeding in MIPS, including:

  • Care coordination techniques
  • Creating and using EHR functionalities
  • Collaborating with community partners
  • Engaging staff
  • Aligning MIPS with other work to help patients & practices succeed

Tuesday, October 15, 2019, 2:30 – 3:30 p.m. CST
Thursday, October 17, 2019 10:00 – 11:00 a.m. CST

Notice: XML Format No Longer Supported for QPP Submissions

Beginning January 2, 2020, QPP submissions must be uploaded to the website in either QPP JSON or QRDA III XML formats. This change will improve API performance & eliminate XML-related security vulnerabilities.

Note: This does not apply to QRDA III XML. The QRDA III XML converter tool will remain available to convert QRDA III XML to QPP JSON.

If you’re unsure which file type your EHR generates, please reach out to your vendor for assistance.

Resources: New to the QPP Library

The following resources were updated or added to the QPP Resource Library in August:

Resources: New to the QPP Library

This material was prepared by Telligen QPP-SURS Resource Center, the Quality Payment Program for Iowa, Nebraska, North Dakota and South Dakota, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. HHSM-500-2017-00012C.

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