MACRA Minute September 2020

Rural Health Flexibilities for COVID-19

The Centers for Medicare & Medicaid Services Office of Minority Health (CMS OMH) has released a Rural Crosswalk: CMS Flexibilities to Fight COVID-19. This new resource documents all current COVID-19-related waivers and flexibilities issued by CMS that impact Rural Health Clinics, Federally Qualified Health Centers, Critical Access Hospitals, rural hospitals, and long-term care facilities. This resource describes the significance of each provision for these rural providers and facilities. This new resource can be found here: https://www.cms.gov/files/document/2020-08-12rural-crosswalk.pdf

The Crosswalk is divided into six sections for easy navigation:

  • Telehealth
  • CMS Hospitals Without Walls
  • Patients Over Paperwork
  • Workforce
  • Payment
  • Additional guidance

CMS OMH created the Rural Crosswalk to boost providers’ understanding of the many CMS regulatory waivers and new rules that have been issued in response to COVID-19 since the start of the emergency declaration. For more information and resources for rural providers, please visit go.cms.gov/ruralhealth. You can also contact us at RuralHealth@cms.hhs.gov or reach out to one of the CMS Regional Rural Health Coordinators.

Final Feedback

As a reminder, MIPS final feedback was released in August. If you have not done so already, please review your score and payment adjustment. You can access your 2019 MIPS performance feedback and final score by:

  • Going to cms.gov/login
  • Logging in using your HCQIS Access Roles and Profile (HARP) system credentials; these are the same credentials that allowed you to submit your 2019 MIPS data

If you don’t have a HARP account, please refer to the Register for a HARP Account document in the QPP Access User Guide and start the process now.

To learn more about performance feedback, review the 2019 MIPS Performance Feedback Resources.

COVID-19 Flexibilities

CMS is implementing multiple flexibilities for the Quality Payment Program in response to the COVID-19 pandemic. They determined that the MIPS automatic extreme and uncontrollable circumstances policy would be applied to all individual MIPS eligible clinicians for the 2019 performance period, and reopened the 2019 extreme and uncontrollable circumstances application to allow requests for reweighting of the MIPS performance categories to 0%.

The 2019 MIPS final scores available on the Quality Payment Program website reflect these COVID-19 flexibilities. Learn more about the COVID-19 flexibilities in the COVID-19 Response Fact Sheet and COVID-19 Response Webpage.

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

Targeted Review

MIPS eligible clinicians, groups, and virtual groups (along with their designated support staff or authorized third-party intermediary), including APM participants, may request CMS to review the calculation of their 2020 MIPS payment adjustment factor(s) through a process called targeted review.

When to Request a Targeted Review

If you believe an error has been made in your MIPS payment adjustment factor(s) calculation, you can request a targeted review until October 5, 2020. Some examples of previous targeted review circumstances include the following:

  • Errors or data quality issues for the measures and activities you submitted
  • Eligibility and special status issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment)
  • Being erroneously excluded from the APM participation list and not being scored under the APM Scoring Standard
  • Performance categories were not automatically reweighted even though you qualify for automatic reweighting due to extreme and uncontrollable circumstances

Note: This is not a comprehensive list of circumstances. CMS encourages you to submit a request form if you believe a targeted review of your MIPS payment adjustment factor (or additional MIPS payment adjustment factor, if applicable) is warranted.

How to Request a Targeted Review

You can access your MIPS final score and performance feedback and request a targeted review by:

  • Going to the Quality Payment Program website
  • Logging in using your HCQIS Access Roles and Profile System (HARP) credentials; these are the same credentials that allowed you to submit your MIPS data. Please refer to the QPP Access Guide for additional details.

CMS may require documentation to support a targeted review request. If the targeted review request is approved, your final score and/or associated payment adjustment (if applicable) may be updated, as soon as technically feasible. Please note that targeted review decisions are final and not eligible for further review.

For more information about how to request a targeted review, please refer to the 2019 Targeted Review User Guide. For more information on payment adjustments please refer to the 2021 MIPS Payment Adjustment Fact Sheet.

Questions?

Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

Cost Measure Field Testing

CMS is conducting cost measures field testing starting August 17 to September 18, 2020. Clinicians and clinician groups who meet the attribution requirements for at least one of the measures listed below will receive a Field Test Report. All stakeholders are invited to provide feedback on the draft measure specifications through an online survey, which closes on September 18, 2020 at 11:59 p.m. Eastern Time (ET). Participation is voluntary.

The following cost measures are being field tested:

  1. Asthma/Chronic Obstructive Pulmonary Disease (COPD)
  2. Colon and Rectal Resection
  3. Diabetes
  4. Melanoma Resection
  5. Sepsis

Access Field Test Reports: Clinicians can download their Field Test Report(s) via the Quality Payment Program website if they meet the minimum number of episodes outlined below:

  • 10 episodes for procedural and acute inpatient medical condition cost measures
  • 20 episodes for chronic condition cost measures

You may provide feedback through this online survey by 11:59 p.m. ET on September 18, 2020. A document containing specific questions about the measures for stakeholders to reference while reviewing the materials is available on the MACRA Feedback Page.

September LAN Webinar

Maximizing Your MIPS Score: Advice for Solo and Small Group Practices

This event will focus on the basic requirements for each performance category, how to use telehealth measures and activities, suggestions for targeting measures and activities that make sense for your practice, and advice on applying for a hardship application. 

September 15th, 2020 2:30 PM to 3:30 PM CST

September 17th, 2020 10:00 AM to 11:00 AM CST

Telligen Webinars

Understanding 2019 MIPS Performance Feedback

In this presentation, we walk you through how to access your 2019 MIPS final feedback, explain the details you see for each of the performance categories and describe the targeted review process if you do not believe your score is accurate.

This on-demand presentation can be found here.

Also, watch for our upcoming presentation titled Overview of the 2021 Proposed Rule. It will be posted to our website soon.

New Resources in the QPP Resource Library

The following resources were updated or added in August

MIPS Value Pathways Overview Factsheet

2020 Clinical Quality Measure Specifications and Supporting Documents

2020 Facility-Based Quick Start Guide

2020 Quality Quick Start Guide

2020 CMS Web Interface Measure Specifications and Supporting Documents

2020 Registration Guide for CMS Web Interface and CAHPS for MIPS Survey

2020 QPP Network Security Update Fact Sheet

QPP COVID-19 Response

2020 MIPS Cost User Guide

2020 MIPS Participation and Eligibility User Guide

2020 MIPS Promoting Interoperability User Guide

2020 Medicare Part B Claims Measure Specifications and Supporting Documents

2020 Qualified Clinical Data Registries

2020 Qualified Registries

2020 QCDR Measure Specifications

2020 CMS Web Interface Quick Start Guide

2021 MIPS Payment Adjustment Fact Sheet

2019 Target Review User Guide

2019 MIPS Performance Feedback Resources

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