March 2021 MACRA Minute Newsletter

CMS to Apply MIPS Automatic Extreme and Uncontrollable Circumstances Policy for the 2020 Performance Period in Response to COVID-19; Reopens Application

CMS continues to offer flexibilities to provide relief to clinicians responding to the 2019 Coronavirus (COVID-19) pandemic. CMS is applying the MIPS automatic extreme and uncontrollable circumstances (EUC) policy to all MIPS eligible clinicians for the 2020 performance period. They are also reopening the MIPS EUC application for individual MIPS eligible clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities through March 31, 2021 at 8 p.m. ET. Please note that applications received between now and March 31, 2021 won’t override previously submitted data for individuals, groups, and virtual groups.

What does this mean for you?

If you have not submitted any data:

  • Individual MIPS eligible clinicians:
    • You don’t need to take any additional action to qualify for the automatic EUC policy.
    • You will be automatically identified and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data as an individual in 2 or more performance categories, or 2) your practice reports as a group, by submitting data for one or more performance category.  
  • Groups:
    • You don’t need to take any further action if you’re not able to submit data for the 2020 performance period.
    • Group participation is optional, and your individual MIPS eligible clinicians qualify for the automatic EUC policy.
      • They will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) they submit data in 2 or more performance categories as individuals, or 2) the practice reports as a group, by submitting data for one or more performance category.

  • Virtual Groups: If you’re unable to submit data for the 2020 performance period, you must submit an EUC application for all 4 performance categories by the deadline.

If you have submitted data:

  • Individual MIPS eligible clinicians that have submitted data for a single performance category (such as Medicare Part B Claims measures submitted throughout the 2020 performance period):
    • You don’t need to take any additional action to be eligible for the automatic EUC policy.
    • You’ll be automatically identified and have all 4 performance categories reweighted to 0% and will receive a neutral payment adjustment for the 2022 MIPS payment year unless 1) you submit data for another performance category, or 2) your group submits data for one or more performance category.

  • Individual MIPS eligible clinicians that have submitted data as an individual for 2 or 3 performance categories:
    • You’ll receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year based on the data you’ve submitted.
    • You’ll only be scored in the performance categories for which data are submitted.
    • You can’t submit an application to override previously submitted data.
  • Groups and virtual groups that have submitted data for a single performance category:
    • If you’re not able to complete data submission for other performance categories, you can submit an application to request reweighting in all 4 performance categories.
    • This includes small practices that were automatically scored as a group on Medicare Part B Claims measures submitted throughout the 2020 performance period.
    • If you don’t submit an application, your group will be scored in all performance categories unless you are eligible for reweighting in one or more performance categories.
    • If your application is approved and data isn’t submitted for another performance category, your MIPS eligible clinicians will receive a neutral payment adjustment for the 2022 MIPS payment year.
  • Groups and virtual groups that have submitted data for 2 or 3 performance categories:
    • Your MIPS eligible clinicians will receive a MIPS final score and MIPS payment adjustment for the 2022 MIPS payment year.
    • Your group will be scored in all performance categories unless you qualify for reweighting in one or more performance categories.
    • You can’t submit an application to override previously submitted data.

Additional Resources

Please reach out to us at Telligen if you have any questions about your specific situation or to ask if you should submit an application. You can contact us via phone at 1-844-358-4021 Monday through Friday 8-4pm CST or via email at qqp-surs@telligen.com

You may also contact the Quality Payment program at 1-866-288-8292 (TRS: 711), Monday through Friday, 8:00 AM-8:00 PM ET or by e-mail at: QPP@cms.hhs.gov.

2020 Data Submission

Reminder data for Quality, Promoting Interoperability and Improvement Activities for MIPS must be submitted by 7:00 p.m. CST on March 31, 2021.

How to Submit Your 2020 MIPS Data

Clinicians will follow the steps outlined below to submit their data:

  1. Go to the Quality Payment Program webpage.
  2. Sign in using your QPP access credentials (see below for directions).
  3. Submit your MIPS data for the 2020 performance year or review the data reported on your behalf by a third party.

2020 Data Submission FAQs

CMS Data Submission Videos   

Telligen Data Submission Webinar

                MIPS Data Submission for Year 4

Suppressed Measures for 2020 Performance Year

In the Calendar Year 2019 Physician Fee Schedule Final Rule (83 FR 59847), the Centers for Medicare & Medicaid Services established a policy that provides for the suppression of measures in certain circumstances.  Starting with the 2019 performance period, for measures significantly impacted by clinical guideline changes or other changes where CMS believes that adherence to guidelines in the existing measures could result in patient harm or otherwise cause misleading results as to what is measured as good quality of care, CMS will reduce the denominator of available measure achievement points for the quality performance category by 10 points for each impacted measure that is submitted by MIPS eligible clinicians and groups.  Such policy will “hold harmless” any clinician or group submitting data on a suppressed measure.

Measures affected by this policy in 2020 are: Measure 69: Hematology: Multiple Myeloma: Treatment with Bisphosphonates, when reported via MIPS CQM; Measure 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan, when reported via CMS Web Interface; Measure 419: Overuse of Imaging for the Evaluation of Primary Headache, when reported via Medicare Part B Claims. Measure 458: All-cause Hospital Readmission, which is scored via Administrative Claims for groups of 16 or more clinicians.

You can read more about why these measures are suppressed for the 2020 performance year in the 2020 Suppressed MIPS Quality Measures document.

March Telligen QPP Connect Live Call

As part of the Performers of Excellence Award we will host a new call-in series called Telligen QPP Connect Live!  Each month we will highlight a topic with a few slides to kick off the call/start conversation and then you can ask questions (on the topic or anything else you would like).  These calls will happen the 3rd Wednesday of every month from 12:00 – 1:00 Central. The call on March 17th will highlight Security Risk Analysis. Please use the following information to join via computer or phone.

Join Zoom Meeting
Phone one-tap:US: +13462487799,,95908897340# or +16699006833,,95908897340#
Meeting URL:https://dsu.zoom.us/j/95908897340?pwd=dkVZSm5CM3EyQUpEQk1BZVFWdzh6UT09
Meeting ID:959 0889 7340
Passcode:761463
Join by Telephone
For higher quality, dial a number based on your current location.
Dial:
US: +1 346 248 7799 or +1 669 900 6833 or +1 253 215 8782 or +1 312 626 6799 or +1 929 205 6099 or +1 301 715 8592
Meeting ID:959 0889 7340

Telligen Webinars

MIPS Data Submission Year 4

This web presentation provides an overview on how to successfully report Merit-based Incentive Payment System data for the Quality, Improvement Activities, and the Promoting Interoperability performance categories.  

February Connect Live! Call Recording

In this new monthly call/webinar format, we provide an overview of the data submission process and answer some frequently asked questions about data submission.

New Quality Measures for 2021

480: Risk-standardized complication rate following elective primary total hip arthroplasty and/or total knee arthroplasty for Merit-based Incentive Payment System

Outcome Measure collected from claims data for a 3-year performance period

For groups and individual clinicians

25 case minimum to be scored on the measure

The measure’s numerator assesses the occurrence of complications in the 90 days following the index admission date; therefore, ending the 3-year performance period on September 30th of the calendar year will allow time for numerator assessment. This approach balances measure reliability with maximizing the number of clinicians or clinician groups measured.

  • 479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission Rate for the Merit-Based Incentive Payment System Groups
    • Outcome measure collected from claims data for a 1-year performance period
    • For groups of 16 or more clinicians
    • 200 case minimum to be scored on the measure
    • Attributes outcomes to MIPS participating clinician groups and assesses each group’s readmission rate. The measure comprises a single summary score, derived from the results of five models, one for each of the following specialty cohorts: medicine, surgery/gynecology, cardio-respiratory, cardiovascular, and neurology

New Resources in the QPP Resource Library

The following resources were updated or added in January.

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