October 2021 MACRA Minute

PY 2020 Performance Category Reweighting Requests Due to COVID-19 Will Be Accepted Through 11/29/2021

The COVID-19 pandemic continues to impact all clinicians across the United States and territories, and  the Centers for Medicare & Medicaid Services (CMS) recognizes that not everyone may have been able to submit an Extreme and Uncontrollable Circumstances (EUC) Exception Application for performance year (PY) 2020 before the March 31, 2021, deadline. As part of ongoing support for clinicians who are on the front lines of this public health emergency (PHE), CMS is allowing clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities to request Merit-based Incentive Payment System (MIPS) performance category reweighting for PY 2020 under the EUC policy now through November 29, 2021, at 8 p.m. ET.

There will be a different process for submitting these requests, so please keep reading for more information about:

Who Can Request Reweighting?

While any clinician, group, virtual group or APM Entity can request performance category reweighting during this time period due to the COVID-19 PHE, the following types of groups in particular may want to consider submitting a request:

  • Small practices that reported Medicare Part B claims measures for the quality performance category but didn’t report group-level data for other performance categories. Some small practices may not have fully understood the implications of their PY 2020 claims reporting in the context of some of the PY 2019 policies CMS introduced at the onset of the COVID-19 PHE. As a result, these small practices may wish to request performance category reweighting on behalf of the entire group.
  • Virtual groups that weren’t able to submit an EUC application by the March 31st deadline or their PY 2020 data due to the ongoing COVID-19 PHE. Clinicians that were approved to participate as a virtual group will be scored as a virtual group, regardless of data submission. Some virtual groups with clinicians on the front lines of the COVID-19 PHE may have missed the March 31st deadline for submitting an EUC Exception Application or were unaware that the automatic EUC policy didn’t apply to their MIPS eligible clinicians.

How Does Performance Category Reweighting Work?

In accordance with EUC policies for individuals, groups and virtual groups, CMS won’t reweight any performance category for which data have been received. This applies to clinicians who report as individuals and are covered by CMS’ automatic EUC policy and to groups and virtual groups that request and receive reweighting. Please note that when fewer than 2 performance categories are scored (for example, one category is weighted at 100% of the final score, and the others are weighted at 0%), the clinician or group will earn a PY 2020 final score equal to the performance threshold and the MIPS eligible clinician(s) will receive a neutral payment adjustment in payment year 2022, unless a higher final score is available. As a reminder, CMS has reweighted the cost performance category to 0% for all clinicians, groups, and virtual groups in PY 2020.

  • Example: A small practice received a group score in the quality performance category from reporting Medicare Part B claims measures under CMS’ existing policies. The quality performance category can’t be reweighted because CMS has received data. However, if the improvement activities and Promoting Interoperability performance categories were approved for reweighting to 0% (and no data was submitted for either of those categories), the quality performance category would be weighted at 100% of the final score. As a result, the group would receive a final score equal to the performance threshold and the MIPS eligible clinician(s) in the group would receive a neutral payment adjustment in payment year 2022, unless a higher final score is available. 

In accordance with the EUC policies for APM Entities, data submission for an APM Entity won’t override performance category reweighting. If approved, the MIPS eligible clinicians in the APM Entity will receive a score equal to the performance threshold and a neutral MIPS payment adjustment in the 2022 payment year.

How Can I Request PY 2020 Performance Category Reweighting?

Due to technical limitations, CMS is unable to reopen the 2020 EUC Exception Application form in the systems. Because of these technical limitations, CMS is allowing stakeholders to submit 2020 EUC reweighting requests through the Targeted Review form until 11/29/2021. You can access this form by signing in to qpp.cms.gov. (The EUC Exception Application form currently accessible when you sign in to qpp.cms.gov is for PY 2021 applications only. Don’t use the Exception Application form to request PY 2020 reweighting.)

When using the Targeted Review form to submit an EUC reweighting request for PY 2020, you’ll need to:

  • Select the Performance Categories for which you’re requesting reweighting.
  • Select “Extreme and uncontrollable circumstances” in the Issue Selection.
  • State explicitly in the Description that you’re submitting an EUC application due to the continuing COVID-19 PHE. (In addition, CMS encourages you to reiterate the performance categories for which you are requesting reweighting: quality, improvement activities, and/or Promoting Interoperability.)

Please review 2020 Extreme and Uncontrollable Circumstances: Reweighting Requests Extension Guide (PDF) for step-by-step instructions with screenshots.

What About Automatic EUC Performance Category Reweighting?

CMS applied the automatic EUC policy to all individual MIPS eligible clinicians for PY 2020. Under this policy, CMS reweighted to 0% any performance category for which data wasn’t submitted, and these performance categories don’t contribute to the clinician’s individual final score. However, the automatic EUC policy only applies to those clinicians who were eligible to participate in MIPS as individuals; it doesn’t apply to clinicians who were only eligible to participate as a group or APM Entity, or who elected to participate as a virtual group.

There’s no need to request reweighting for PY 2020 for a clinician who was eligible to participate in MIPS as an individual because CMS has already applied reweighting under the automatic EUC policy.

Questions?

Contact Michelle Brunsen at 515-453-8180 or by e-mail at mbrunsen@telligen.com. You may also 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 a.m. and after 2 p.m. ET. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

CMS Updates 2020 MIPS Performance Feedback and 2022 MIPS Payment Adjustments

Recently, the Centers for Medicare & Medicaid Services (CMS) released performance feedback for clinicians included in the Merit-based Incentive Payment System (MIPS) for the 2020 performance year (PY).

Along with releasing performance feedback, CMS opened the targeted review period. A targeted review provides the opportunity for clinicians, groups, virtual groups or those participating in certain Alternative Payment Models (APMs) to request review of their MIPS payment adjustment factor(s), if they believe there is an error with their final score and associated MIPS payment adjustment.

The requests received through PY 2020 targeted review process caused CMS to take a closer look at a couple of prevailing concerns. The targeted review process worked as intended, as the incoming requests quickly alerted CMS to these issues and allowed CMS to take immediate action. Based on these requests, CMS reviewed the concerns and identified 2 issues to correct so that final scores align with CMS policies. In response, CMS corrected MIPS scoring logic which resulted in changes to performance feedback, including 2020 final scores and 2022 MIPS payment adjustments.

From the onset of QPP, CMS goals have included creating a program that is fully transparent and provides accurate information. CMS believes that the corrections identified below are essential to achieving that goal. CMS will continue to work closely with the clinician community to learn from one another and ensure operational excellence in implementation.

Complex Patient Bonus Correction for Medicare Shared Savings Program ACOs

Specifically, CMS determined that the complex patient bonus wasn’t added to the final scores of Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organizations (ACOs). This issue affected every Shared Savings Program ACO with MIPS eligible clinicians.  In their updated performance feedback, Shared Savings Program ACOs will see up to 10 complex patient bonus points reflected in their performance feedback and added to their final scores, if applicable.  (There are approximately 20 ACOs that didn’t qualify for any complex patient bonus points.) As a reminder, your final score can’t exceed 100 points.

Patient-Reported Outcome Measure Correction

CMS also determined that the system didn’t recognize patient-reported outcome measures as outcome measures. CMS corrected the scoring logic, which resulted in 2 potential changes to quality performance category scoring for approximately 30,000 MIPS eligible clinicians:

  • Patient-reported outcome measures submitted in addition to another outcome measure became eligible for 2 high priority bonus points. (As a reminder, these bonus points are capped at 10% of your quality denominator.)
  • Patient-reported outcome measures became eligible to fulfill the requirement to report an outcome measure.

The majority of affected clinicians will see a modest increase in their quality performance category score and MIPS final score as a result of this correction. However, approximately 4,400 clinicians will see a decrease in their quality performance category score and MIPS final score. This occurred when a lower-scoring patient-reported outcome measure replaced a higher-scoring high priority measure in their top 6 measures, fulfilling the requirement to report an outcome measure. (A high priority measure is only selected for the top 6 measures in the absence of an available outcome measure.)

Impact to MIPS Payment Adjustments

The statute requires MIPS to be a budget neutral program, which means that the projected negative adjustments must be balanced by the projected positive adjustments. As a result of changes to MIPS final scores from these 2 corrections, CMS reassessed the associated MIPS payment adjustments to maintain budget neutrality. Some clinicians that weren’t affected by the issues identified will see slight changes in their payment adjustment due to the reapplication of budget neutrality. 

Additional Adjustment for Exceptional Performance

In addition to the standard MIPS payment adjustment, MIPS eligible clinicians with a final score between 85 and 100 points receive an additional adjustment for exceptional performance. This adjustment isn’t subject to budget neutrality but is scaled to ensure the appropriate distribution of available funds. When CMS corrected final scores for alignment with the existing policies, more clinicians moved into the exceptional performance pool, causing a slight decrease in the exceptional performance adjustment.

Sign-In to View Updated Feedback

The 2020 final scores and 2022 MIPS Payment Adjustments revisions were made to the performance feedback on the Quality Payment Program (QPP) website on September 27, 2021. CMS encourages you to sign-in to the Quality Payment Program website as soon as possible to review your performance feedback. If you believe an error still exists with your 2022 MIPS payment adjustment calculation, the targeted review process is available to you.

Targeted Review Extension

To offer additional time for clinicians, groups, virtual groups and APM entities and their participants to access and review their performance feedback, CMS is extending the targeted review deadline to November 29, 2021, at 8:00pm (ET).  You can submit a targeted review by signing in to the Quality Payment Program website.

Additional Resources

CMS also has a number of resources available on the QPP Resource Library to help you understand your performance feedback and the targeted review process, including:

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 Open: Virtual Group Election Period for the MIPS 2022 Performance Year

If you’re interested in forming a virtual group for the 2022 Merit-based Incentive Payment System (MIPS) performance year, the election period opened October 1, 2021. To form a virtual group, an election must be submitted to CMS via e-mail between October 1, 2021, and December 31, 2021 (11:59 p.m. ET)

NOTE: A virtual group must submit an election to CMS for each performance year that it intends to participate in MIPS as a virtual group (as required by statute). If your virtual group was approved for the 2021 MIPS performance year and intends to participate in MIPS as a virtual group for the 2022 MIPS performance year, your virtual group is still required to submit an election to CMS for the 2022 MIPS performance year between October 1, 2021, and December 31, 2021 (11:59 p.m. ET).   

What Is a Virtual Group?

A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) consisting of the following:

  • Solo practitioners who are MIPS eligible (a solo practitioner is defined as the only clinician in a practice); and/or
  • Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPS eligible). A group is considered to be an entire single TIN.

A virtual group has the flexibility to determine its own makeup.  A solo practitioner or group can only participate in one virtual group during the performance year. 

What Are the Advantages of Participating in a Virtual Group?

Participating in MIPS as a virtual group has the following advantages:

  • Can increase performance volume in order to be reliably measured; and
  • Provides an opportunity for members of a virtual group to collaborate, share resources, and potentially increase performance under MIPS.

What Is the Virtual Group Election Process?

The following highlights key items that a virtual group needs to complete prior to the submission of an election:

  • Establish a formal written agreement between each TIN within the virtual group (see Agreement Sample Template in the Virtual Group Election Process Guide within the 2022 Virtual Group Toolkit).
  • Identify an official virtual group representative.

The following outlines the elements that need to be included in an election:

  • Acknowledgement that a formal written agreement has been established between each TIN within the virtual group.
  • The name and contact information for the official virtual group representative.
  • The name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN.

Once complete, the virtual group must submit the election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by 11:59 p.m. ET on December 31, 2021 (see Election E-mail Sample in the Virtual Group Election Process Guide within the 2022 Virtual Group Toolkit).

For further information regarding virtual group participation in MIPS, virtual group reporting requirements, the election process, checklists for virtual groups to consider, and sample templates, download the 2022 Virtual Group Toolkit.

Need Help?

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 a.m. and after 2 p.m. ET. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Upcoming MIPS Important Dates and Deadlines

The Centers for Medicare & Medicaid Services (CMS) would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines:

  • October 1 2022 virtual group election period opened. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who want to participate in MIPS as a virtual group for the 2022 performance year must submit their election to CMS.
  • October 3 – The last day to begin data collection for a continuous 90-day performance period for the improvement activities and Promoting Interoperability performance categories.
    • Note: Most, but not all, improvement activities have a continuous 90-day performance period, but several improvement activities require completion of modules where there’s a year-long or alternate performance period. The performance period is 90 days unless otherwise stated in the activity description.
  • December 31 – 2021 Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances (EUC) Applications close. Clinicians, groups, and virtual groups who believe they’re eligible for these exceptions may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. Alternative Payment Model (APM) Entities can also request reweighting of all performance categories through the EUC application. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool but may not appear in the tool until the data submission period begins in 2022.
  • December 31 – 2022 virtual group election period closes.
  • January 3, 2022 – 2021 MIPS performance year data submission period begins.
  • March 31, 2022 – 2021 MIPS performance year data submission period closes.

For More Information

  • To learn more, visit the QPP website.
  • QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. ET.

QPP Website Will No Longer Support IE 11 Browser

Microsoft is ending support for the Internet Explorer (IE) 11 browser in June 2022. As a result, this browser won’t be up to date with the latest security updates. Due to these security concerns, as of October 13, 2021, users won’t be able to access the Quality Payment Program (QPP) website, qpp.cms.gov using the IE 11 browser.

What Does this Mean for Me?

A very small percentage of users (2%) access qpp.cms.gov, through an IE 11 browser. By discontinuing support, CMS will be able to improve security and the user experience for the 98% of users who access the website through other browsers.

The QPP website will continue to support modern browsers such as Google Chrome and Microsoft Edge.

  • IE11 users will need to download one of these browsers in order to access qpp.cms.gov on or after October 13, 2021.

Questions?

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 a.m. and after 2 p.m. ET. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Now Available: 2021 Change Review Process (CRP)

The Centers for Medicare & Medicaid Services (CMS) announced the availability of the 2021 Change Review Process (CRP) for electronic clinical quality measures (eCQMs). The CRP provides eCQM users the opportunity to review and comment on draft changes to the eCQM specifications and supporting resources under consideration by the measure steward. The goal of the CRP is for eCQM implementers to comment on the potential impact of draft changes to eCQMs so CMS and measure stewards can make improvements to meet CMS’s intent of minimizing provider and vendor burden in the collection, capture, calculation, and reporting of eCQMs.

This latest installment of the CRP for eligible professional/eligible clinician and eligible hospital/critical access hospital issues will be conducted using the web-based public comment tools on the ONC Project Tracking System eCQM Issue Tracker during fall 2021. Note that an ONC Project Tracking System account is required to post a question or comment. New users can create an account via the ONC Project Tracking System website.

CRP updates regarding issues available for public comment will be posted on the ONC Project Tracking System eCQM Issue Tracker summary page. To subscribe to weekly CRP digest emails containing updates on CRP activities, please email CRP@mathematica-mpr.com.

For More Information

To find out more about eCQMs, visit the Electronic Clinical Quality Improvement (eCQI) Resource Center. To report questions and comments regarding eCQMs, visit the eCQM Issue Tracker. To submit technical questions and issues related to the development and implementation of the Clinical Quality Language (CQL) standard, visit the CQL Issue Tracker.

Quality Payment Program: 2021 Performance Period Merit-based Incentive Payment System (MIPS) Quality Measures Impacted by the Annual ICD-10 Coding Update

In the Calendar Year (CY) 2021 Quality Payment Program Final Rule (85 FR 84898 through 84900), the Centers for Medicare & Medicaid Services (CMS) finalized the policy allowing for the review of quality measures for significant impacts due to International Classification of Diseases, Tenth Revision (ICD-10) coding changes during the performance period. Performance for these quality measures will be assessed based only on the first 9 months of the 12-month performance period.

For the 2021 MIPS performance period, CMS has not identified any quality measures requiring performance data to be suppressed for the last quarter of the performance period due to the annual ICD-10 code update.

Additional information regarding this policy can be found in the 2021 MIPS Quality Measures Impacted by ICD-10 Updates located on the QPP Resource Library.

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

MIPS Facility-Based Scoring Isn’t Available for Performance Year (PY) 2021

In response to the impact of the ongoing COVID-19 public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) finalized a measure suppression policy in the Fiscal Year (FY) 2022 Inpatient Prospective Payment System (IPPS)/Long-Term Care Hospital (LTCH) PPS final rule for several hospital reporting programs, including the Hospital Value-Based Purchasing (VBP) Program. This policy allows CMS to suppress the use of measure data if the agency determines that circumstances caused by the COVID-19 PHE have affected those measures and the resulting quality scores significantly. CMS also finalized the suppression of 7 measures for the FY 2022 Hospital VBP Program under this policy.

CMS believes that calculating a total performance score in the Hospital VBP Program for hospitals using only data from the remaining measures, all of which are in the Clinical Outcomes Domain, wouldn’t result in a fair national comparison. Therefore, CMS finalized a special scoring policy for FY 2022 that won’t calculate a total performance score for any hospital for FY 2022.

How does this affect MIPS facility-based scoring in PY 2021?

CMS uses the total performance score from the Hospital VBP Program to calculate Merit-based Incentive Payment System (MIPS) facility-based scores for facility-based clinicians and groups in the quality and cost performance categories. The FY 2022 total performance score is what CMS would use to determine these scores for the 2021 MIPS performance year.

  • Because the FY 2022 total performance score from the Hospital VBP Program won’t be available, CMS won’t be able to calculate MIPS facility-based scores for the 2021 MIPS performance year.

What does this mean for MIPS reporting?

Facility-based clinicians and groups will need to submit data on MIPS quality measures (except for administrative claims-based measures that have a benchmark, which are automatically calculated for clinicians and groups that meet the case minimum) to receive a score other than zero for the quality performance category.

CMS will automatically calculate a score for the cost performance category for facility-based clinicians and groups that meet the case minimum for at least one MIPS cost measure; there aren’t any data collection or submission requirements for the cost performance category. If the facility-based clinician or group doesn’t meet the case minimum for any cost measures, the cost performance category will be reweighted to 0% and the weight redistributed to other performance categories.

  • Facility-based clinicians and groups without available and applicable measures can request performance category reweighting by submitting an extreme and uncontrollable circumstances (EUC) application.
  • Please be sure to cite “COVID-19” as the triggering event, as the decision to suppress measures in the Hospital VBP Program was in response to the COVID-19 PHE.

Additional Resources

October 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 October’s call we will review MIPS Value Pathways (MVPs). As always, we will have time at the end of the presentation for any MIPS questions you have. Please join us on Wednesday, October 20th 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/topics in the Webinar Library on the QPP website.

Telligen Webinars

Our monthly webinar for September provided details on preparing for 2021 MIPS data submission. 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 September:

2022 Virtual Group Toolkit

2021 Promoting Interoperability Quick Start Guide

2020 Scoring Update and EUC Reweighting Requests Extension List Serv

2020 EUC Reweighting Requests Extension Guide

2020 MIPS Performance Feedback FAQs

2020 Targeted Review User Guide

2021 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet

2021 MIPS Group Participation Guide

2021 Traditional MIPS Scoring Guide

2021 MIPS Quality Measures Impacted by ICD-10 Updates

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