August 2021 MACRA Minute

Now Available: 2020 MIPS Performance Feedback, Final Score, and 2022 MIPS Payment Adjustment Information

The Centers for Medicare & Medicare Services (CMS) has released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for performance year 2020 and associated MIPS payment adjustment information for payment year 2022.

You can view your MIPS performance feedback,  final score, and payment adjustment on the Quality Payment Program website

You can access your 2020 MIPS performance feedback, 2020 final score, and 2022 payment adjustment information 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 2020 MIPS data

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

To learn more about the information in your performance feedback, review the following 2020 MIPS Performance Feedback Resources:  

COVID-19 Flexibilities

CMS has continued to implement flexibilities for the Quality Payment Program in response to the COVID-19 pandemic. CMS applied the MIPS automatic extreme and uncontrollable circumstances policy to all individual MIPS eligible clinicians for the 2020 performance period, and CMS reopened the 2020 Extreme and Uncontrollable Circumstances Exception application to allow requests for reweighting of the MIPS performance categories to 0% for groups, virtual groups and APM Entities.

The 2020 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.

Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Now Available: 2020 MIPS Targeted Review

If you participated in the Merit-based Incentive Payment System (MIPS) in 2020, you can now review your performance feedback, including your MIPS final score and payment adjustment factor(s), on the Quality Payment Program website.

For MIPS eligible clinicians, your 2020 final score determines the payment adjustment you’ll receive in 2022, with a positive, negative, or neutral payment adjustment being applied to the Medicare paid amount for covered professional services furnished in 2022.

MIPS eligible clinicians, groups, and virtual groups (along with their designated support staff or authorized third party intermediary), including APM participants, may request that CMS review the calculation of their 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 the calculation of your MIPS payment adjustment factor(s), you can request a targeted review until October 1, 2021. Some examples of previous targeted review circumstances include the following:

  • Data was submitted under the wrong Taxpayer Identification Number (TIN) or National Provider Identifier (NPI)
  • Eligibility and special status issues (e.g., you fall below the low-volume threshold and shouldn’t receive a payment adjustment)
  • Performance categories weren’t automatically reweighted even though you qualify for reweighting due to extreme and uncontrollable circumstances

Note: This is not a comprehensive list of circumstances. If you have questions about whether a targeted review is warranted for your circumstance, please contact the Quality Payment Program.

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 generally requires documentation to support a targeted review request, which varies by circumstance. You’ll be contacted by a representative with information about any specific documentation required. If the targeted review request is approved and results in a scoring change, CMS will update your final score and/or associated payment adjustment (if applicable), 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 2020 Targeted Review User Guide (PDF). For more information on payment adjustments please refer to the 2022 MIPS Payment Year Payment Adjustment User Guide (PDF).

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.

Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant

Applications for the 2021 MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exceptions are Now Open

Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. Those interested must submit their applications to CMS by December 31, 2021.

Who is Eligible for a Promoting Interoperability Hardship Exception?

MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they’re reporting traditional MIPS or the APM Performance Pathway. Exceptions are granted if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have insufficient Internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues; or
  • Lack control over the availability of CEHRT.

NOTE: If you’re already exempt from submitting Promoting Interoperability data, you don’t need to apply.

Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?

MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:

  • Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  • Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or;
  • Impact your normal process, affecting your performance on cost measures and other administrative claims measures.

NOTE: For the 2021 Performance Year CMS will continue to use the Extreme and Uncontrollable Circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.

How Do I Apply?

In order to apply, you must create a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application. For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances’ or ‘Promoting Interoperability Hardship.’

How Do I Know if I’m Approved?

If you submit an application for either exception, you’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool.

For More Information

Visit the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception QPP webpages for more information and link to the application.

Download the 2021 MIPS Promoting Interoperability Hardship Exception Application Guide and the 2021 Extreme and Uncontrollable Circumstances Exception Application Guide now available on the QPP Resource Library.

CMS Approves Suppressing Quality ID 001: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) and Quality ID 117: Diabetes: Eye Exam Medicare Part B Claims submissions for the 2021 Performance Period

The Centers for Medicare & Medicaid Services (CMS) will suppress the Medicare Part B claims-based submission of the following measures for the 2021 performance period:

  • Quality ID (QID) 001: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%)
  • QID 117: Diabetes: Eye Exam

In January 2021, new Current Procedural Terminology (CPT) Category II Quality Data Codes were introduced as numerator options within the measure specification but were not activated within CMS systems and therefore not usable for the 2021 performance period. Stakeholders expressed concerns that reporting these codes has resulted in rejected claims due to the inactive status.

Measure QIDMeasure NameAffected CPT II Quality Data Code
001Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%)3051F –  Most recent hemoglobin A1c (HbA1c) level greater than or equal to 7.0% and less than 8.0%
001Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%)3052F –  Most recent hemoglobin A1c (HbA1c) level greater than or equal to 8.0% and less than or equal to 9.0%
117Diabetes Eye Exam2023F – Dilated retinal eye exam with interpretation by an ophthalmologist or optometrist documented and reviewed; without evidence of retinopathy  
117Diabetes Eye Exam2025F – 7 standard field stereoscopic photos with interpretation by an ophthalmologist or optometrist documented and reviewed; without evidence of retinopathy
117Diabetes Eye Exam2033F – Eye imaging validated to match diagnosis from  7 standard field stereoscopic photos results documented and reviewed, without evidence of retinopathy

Per CMS policy:

For each measure that is submitted, if applicable, and impacted by significant changes, performance is based on data for 9 consecutive months of the applicable CY performance period. If such data are not available or may result in patient harm or misleading results, the measure is excluded from a MIPS eligible clinician’s total measure achievement points and total available measure achievement points. For purposes of this paragraph (b)(1)(vii)(A), “significant changes” means changes to a measure that are outside the control of the clinician and its agents and that CMS determines may result in patient harm or misleading results. Significant changes include, but are not limited to, changes to codes (such as ICD-10, CPT, or HCPCS codes), clinical guidelines, or measure specifications. CMS will publish on the CMS website a list of all measures scored under this paragraph (b)(1)(vii)(A) as soon as technically feasible, but by no later than the beginning of the data submission period at § 414.1325(e)(1).

Therefore, CMS is suppressing the Medicare Part B claims collection type for QID 001 and QID 117 for the 2021 performance period, and these measures will not be scored. For each suppressed measure that’s submitted for the 2021 performance period, the total available measure achievement points will be reduced by 10 points*. CMS encourages eligible clinicians and groups to choose different quality measures to report for the 2021 performance period. MIPS eligible clinicians do not need to submit any additional documentation or resubmit rejected claims solely for the purpose of adding a quality data code for the 2021 performance period.

For any questions related to this policy, please contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov (Monday-Friday 8 a.m.- 8 p.m. ET). To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

*Please refer to the scoring equations on page 43 of the 2021 MIPS Quality User Guide
https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1432/2021%20MIPS%20Quality%20User%20Guide.pdf

CMS Publishes Policy Changes for Quality Payment Program in 2022 Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) has issued its proposed policies for the 2022 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM).

2022 Policy Highlights

The following are some of the key QPP policies that have been proposed in the NPRM:

  • MIPS Value Pathways (MVPs) begin in 2023 with 7 options for the first year
  • The CMS Web Interface extends as a collection type and submission type for quality measure reporting into the 2022 and 2023 performance years for Shared Savings Program Accountable Care Organizations (ACOs) (for other ACOs and registered groups and virtual groups the CMS Web Interface continues for the 2022 performance period only)
  • Updates to cost measures and improvement activities inventory
  • Revisions to Promoting Interoperability performance category reporting requirements

Submit Comments

CMS is seeking comment on a variety of potential changes in the NPRM, including:

  • Traditional MIPS sunsets after the end of the 2027 performance and data submission periods;
  • The development of new cost measures by stakeholders;
  • The appropriate number of procedures done or conditions treated at the facility types for which CMS is proposing to add affiliation; and
  • The types of utilization data that could be added to Care Compare to inform patients’ healthcare decisions.

You must officially submit your comments in one of the following ways:

  • Electronically, through regulations.gov
  • Regular mail
  • Express or overnight mail
  • Hand or courier

For More Information

Learn more about the 2022 PFS NPRM and the Quality Payment Program proposals by reviewing the following resources:

  • Press release – Provides additional details about the proposed policies for QPP and other CMS initiatives
  • 2022 QPP Proposed Rule Resources:
    • Overview Fact Sheet – Offers an overview of QPP’s proposed policies for 2022
    • Comparison Table – Compares 2022 NPRM proposals to the current policies in 2021
    • MVPs Proposals Table – Provides an overview of the proposed policies in the 2022 NPRM related to MVPs

Questions

Contact the Quality Payment Program at 1-866-288-8292 by e-mail at: qpp@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern Time (ET). Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Submit Comments on Policy Changes for Quality Payment Program in 2022 Physician Fee Schedule Proposed Rule

Provide Feedback on Proposed Changes to the Quality Payment Program by September 13

The Centers for Medicare & Medicaid Services (CMS) recently issued its proposed policies for the 2022 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM). The deadline to submit comments on the proposed rule is September 13, 2021.

Highlights

The following are some of the key QPP policies that have been proposed in the NPRM:

  • MIPS Value Pathways (MVPs) begin in 2023 with 7 options for the first year
  • The CMS Web Interface extends as a collection type and submission type for quality measure reporting into the 2022 and 2023 performance years for Shared Savings Program Accountable Care Organizations (ACOs) (for other ACOs and registered groups and virtual groups the CMS Web Interface continues for the 2022 performance period only)
  • Updates to cost measures and improvement activities inventory
  • Revisions to Promoting Interoperability performance category reporting requirements

CMS is also seeking comment on a variety of potential changes in the NPRM, including:

  • Traditional MIPS sunsets after the end of the 2027 performance and data submission periods;
  • The development of new cost measures by stakeholders;
  • The appropriate number of procedures done or conditions treated at the facility types for which CMS is proposing to add affiliation; and
  • The types of utilization data that could be added to Care Compare to inform patients’ healthcare decisions.

Submit a Formal Comment by September 13

You must officially submit your comments in one of the following ways:

  • Electronically, through regulations.gov
  • Regular mail
  • Express or overnight mail
  • Hand or courier

Electronic comments are due no later than 11:59 p.m. ET on September 13, 2021 and mailed comments must be received by 5:00 p.m. ET, September 13, 2021.

For More Information

Learn more about the 2022 PFS NPRM and the Quality Payment Program proposals by reviewing the following resources:

  • 2022 QPP Proposed Rule Resources:
    • Overview Fact Sheet – Offers an overview of QPP’s proposed policies for 2022
    • Comparison Table – Compares 2022 NPRM proposals to the current policies in 2021
    • MVPs Proposals Table – Provides an overview of the proposed policies in the 2022 NPRM related to MVPs
  • MVP Transition Timeline for Comment Solicitation – Provides a visual display of a timeline for transitioning from traditional MIPS to MVPs that CMS is seeking comment on in the 2022 PFS proposed rule.

Questions

Contact the Quality Payment Program at 1-866-288-8292 by e-mail at: qpp@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern Time (ET). Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

August Telligen QPP Connect Live Call

As part of the Performers of Excellence Award program, we are hosting a call-in series called Telligen QPP Connect Live! Each month we highlight a topic with a few slides to kick off the call/start the 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. On August’s call we will review the 2020 MIPS Performance Feedback Reports. As always, we will have time at the end of the presentation for any MIPS questions you have. Please join us on Wednesday, August 18th at noon CST using the link below

Join Zoom Meeting

https://telligen.zoom.us/j/99104893418?pwd=MFRNZWdOV3ZwaEQ3VkQ3aDJidWJIZz09

Meeting ID: 991 0489 3418

Passcode: 784640

One tap mobile

+19294362866,,99104893418# US (New York)

+16699006833,,99104893418# US (San Jose)

Dial by your location

        +1 929 436 2866 US (New York)

        +1 669 900 6833 US (San Jose)

        877 853 5257 US Toll-free

        888 475 4499 US Toll-free

Meeting ID: 991 0489 3418

CMS Webinars

Reminder you can view previous CMS webinars on various MIPS categories in the Webinar Library on the QPP website. The 2021 MIPS Improvement Activities and Promoting Interoperability Performance Categories Webinar is now posted with recording and slides available.

Telligen Webinars

Our monthly webinar for July provided details on the 2021 MIPS Data Validation Criteria Basics. You can view the recording or download the slides from our website.

New Resources in the QPP Resource Library

The following resources were updated or added in July/early August:

Quality Payment Program Access User Guide

2021 Traditional MIPS Scoring Guide

Draft COVID-19 Vaccination Measure Specifications

2020 Performance Period Benchmarks

2020 MIPS Performance Feedback FAQs

2021 EMA and Denominator Reduction Guide

2022 MIPS Payment Year Payment Adjustment User Guide

2020 Targeted Review User Guide

2021 Quality Benchmarks

2022 Quality Payment Program Proposed Rule Overview Fact Sheet

2022 Quality Payment Program Proposed Rule Resources

MVP Transition Timeline for Comment Solicitation

2022 Quality Payment Program Proposed Rule

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