QPP SURS Newsletter December 2019

QPP SURS Quality Payment Program


Upcoming Events

Doctor Talking to Patient


January 2020 LAN Webinar: Quality Payment Program—MIPS Question and Answer Town Hall Event for Solo and Small Group Practices

Additional Upcoming Events and Links to Past Events

Past QPP SURS events: https://qppsurs.com/webinar-resources/

Small Practice Spotlight: Dr. Rajkumar Bhojraj

photo of Dr. Rajkumar Bhojraj
Dr. Rajkumar Bhojraj

Dr. Rajkumar Bhojraj is a solo family practitioner with two office locations in Maryland. He has prior experience participating in a Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO), and built on that experience when he transitioned to individual reporting in 2019. Below are some tips that Dr. Bhojraj shared for how to prepare your practice for MIPS reporting.

  • Build a relationship with your Technical Assistance Contractor (TAC): Dr. Bhojraj found out about the free assistance available to small practices through an email he received from his local TAC, Qlarant (a subcontractor of IPRO). He reached out to them for help understanding MIPS requirements, and to establish a MIPS workflow for reporting. Charlotte Gjerloev, a Project Manager from Qlarant, helped Dr. Bhojraj determine the best reporting option for his practice, identify and select an improvement activity, and apply for a Promoting Interoperability (PI) hardship exception.
  • Select MIPS measures and activities that align with activities your practice is already doing: Dr. Bhojraj selected the following six MIPS quality measures to report via claims because they were applicable to his small practice, and he had already been reporting these measures to the ACO, so had an established process for documenting these measures.
    • Controlling High Blood Pressure (Quality ID: 236)
    • Body Mass Index (BMI) Screening and Follow-Up Care Plan (Quality ID: 128)
    • Documentation of Current Medications in the Medical Record (Quality ID: 130)
    • Pneumococcal Vaccination Status for Older Adults (Quality ID: 111)
    • Falls: Screening for Future Fall Risk (Quality ID: 318)
    • Colorectal Cancer Screening (Quality ID: 113)
  • Create a personalized coding “cheat sheet” to assist with MIPS claims quality measure documentation and reporting. To ensure accurate claims coding, Qlarant helped Dr. Bhojraj better understand the claims data submission process using CMS resources, such as the 2019 CMS Claims Data Submission Fact Sheet, and the 2019 CMS Medicare Part B Claims Measure Specifications. Qlarant and Dr. Bhojraj worked together to identify the correct quality data codes to include on applicable Part B claim line items for each quality measure.  Dr. Bhojraj created a cheat sheet for himself on how to document MIPS measures and determine the appropriate codes to add to claims. Using the cheat sheet, he identifies the relevant codes on each patient’s file following a visit, and his billing assistant reviews and adds the codes to the claims the next morning.

If you are a solo practitioner new to MIPS reporting like Dr. Bhojraj, consider these strategies to help improve your MIPS score for performance year 2019 and beyond. For free personalized assistance, contact your Technical Assistance Contractor. To find the Technical Assistance Contractor for your region, click here: https://qpp.cms.gov/about/small-underserved-rural-practices.

Quality Payment Program Performance Year (PY) 2020 Final Rule: What’s New for Small Practices?

Since 2017, CMS has offered flexible options for clinicians to ease into MIPS participation. Now that many clinicians are successfully participating, CMS is raising a number of score thresholds. As you prepare for 2020 MIPS reporting, bear in mind these key points:

  • The minimum score to avoid a negative payment adjustment in PY 2020 is 45 points, up from 30 points in PY 2019.
  • The threshold for obtaining an exceptional performance bonus will increase to 85 points in 2020, up from 75 points in 2019.
  • If reporting as a group, at least 50% of clinicians in the group will need to perform any given Improvement Activity in order for all members to receive credit for that activity.
  • Data completeness requirements will increase to 70% of sampled patients for most collection types (i.e., Medicare Part B claims, MIPS CQMs, QCDR, and eCQMs).
  • There are no changes in the weighting of the Quality, Cost, Promoting Interoperability, and Improvement Activities categories (45%, 15%, 25%, and 15%, respectively).
  • CMS will expand reporting of MIPS scores on the Physician Compare site, beginning with your 2018 data, which is expected to be made available starting in late 2019.
  • Small practices can still get additional flexibilities!
    • You can get six bonus points in the Quality Measures category just for being a small practice!
    • Practices that do not meet data completeness requirements for a given quality measure will continue to receive three measure achievement points for submitting data on that measure.
    • Small practices participating individually or in a group can continue to report quality data through the Medicare Part B claims submission type for the MIPS Quality performance category.
    • Small practices can continue to apply for a hardship exception to the Promoting Interoperability performance category.
    • Small practices are only required to submit two improvement activities instead of the four required for larger practices.

In 2020, CMS will be working to develop “MIPS Value Pathways” (MVPs), which were introduced conceptually in the 2020 rulemaking process.  MVPs are intended to simplify MIPS participation and support clinicians moving toward APM participation by helping providers align their activities and reporting around more meaningful population health goals. While the MVPs are still being developed, you can prepare for this change by asking your Technical Assistance Contractor how you might leverage a single improvement activity to improve your performance on MIPS Quality, Promoting Interoperability, and/or Cost categories this year.

If you work in a practice that has 15 or fewer clinicians, you can still count on support from CMS-funded Technical Assistance Contractors. Find yours at: https://qpp.cms.gov/about/small-underserved-rural-practices.

Preparing for the Quality Performance Category in Performance Year (PY) 2020

MIPS is approaching its fourth year and now is a good time to re-evaluate your measure choices before the 2020 performance year begins. Just because you reported on certain measures last year does not mean those measures are still the best for your practice or are still part of the available MIPS quality measures for PY 2020. Here are a few resources that are important to review and can help you select quality measures:

  • To check if the quality measures you previously reported have been removed for PY 2020, please review the list of MIPS measures finalized for removal in Table C  of the PY 2020 Final Rule, starting on page 63398 (PDF version). New measures and specialty measure sets finalized for MIPS can be found in the PY 2020 Final Rule in Tables Group A and Group B, respectively.  
  • CMS has added the following new specialty measure sets: Endocrinology, Nutrition/Dietician, Pulmonology, Chiropractic Medicine, Clinical Social Work, Audiology, and Speech Language Pathology. These sets have been added based in part on the expanded definition of the MIPS-eligible clinician for physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians. If you are one of these clinician types or specialists, please review these measure sets to see if they work best for your practice.
  • The 2020 Quality Performance Category Benchmarks (for applicable measures) are expected to be available on the QPP Resource Library shortly before the performance period begins on January 1, 2020. The benchmarks are used to measure performance and are calculated using historical data submitted to the Quality Payment Program. When you submit measures for MIPS, each one is assessed against a benchmark to determine how many achievement points the measure earns. Understanding these benchmarks can help you estimate your quality score.
  • Take note of topped out measures. CMS will identify topped out measures through the benchmarking process and announce these measures shortly before the start of the performance year on January 1, 2020. This information can also be found in the 2020 Quality Benchmarks file.

Additionally, there are changes to the thresholds for data completeness for PY 2020. Quality measure data reported will be required to meet a 70% data completeness threshold. For example, for each measure you select, you must report a minimum of 70% of the total eligible instances. Reported measures that fall below this threshold will receive 0 points (except for small practices that will continue to receive 3 points). The data completeness thresholds by collection type include:

  • Medicare Part B Claims measures: 70% sample of Medicare Part B patients for the performance period
  • QCDR measures, MIPS CQMs, and eCQMs: 70% sample of clinician’s or group’s patients across all payers for the performance period

To meet these requirements and increase your opportunity to receive a higher quality performance category score, start your data collection on January 1, 2020.  You will need to report on 12 months of quality data for the 2020 performance period (January 1, 2020 – December 31, 2020).

Once you identify the measures most suitable for your practice, review the corresponding measure specifications including elements, reporting frequency, and applicable codes. CMS anticipates that this information will be available on the QPP Resource Library by December. For more information on measure specifications, please visit the Explore Measures & Activities tool, which will be updated in early 2020. Use these tips to meet the Quality performance category requirements and receive a high Quality performance score in 2020!

Questions and Answers from the October 2019 QPP SURS LAN Webinar

The following questions were among those asked by the attendees of the October 2019 LAN webinar, entitled “How to Transform Your Practice Workflow to Succeed in MIPS: Advice for Solo and Small Group Practices.” The answers have been edited here for length and context. For access to the full Q&A document and previous LAN webinar presentations, see the QPP SURS website.

1. I work for a physician and his group of mid-level practitioners. They do not have a clinic practice. They see patients in various nursing facilities, assisted living, and some home patients. I am the only one in office doing the billing, filing, research, gathering MIPS information needed from 11 nursing facilities, as that is where the records and orders and everything pertaining to that patient are kept. I have to do everything for the MIPS reporting, and I am overwhelmed with MIPS. What can I do to make it less confusing when trying to complete the reporting?

It can be challenging for practices with providers who work in multiple settings to aggregate all of their MIPS data for reporting. Oftentimes, claims-based reporting is the easiest way to report for providers operating in multiple settings, including skilled nursing facilities, assisted living facilities, and home and community-based settings. For more information on claims reporting, see the 2019 Claims Data Submission Fact Sheet, as well as the 2019 Medicare Part B Claims Measure Specifications and Supporting Documents.

Additionally, there are several resources on the QPP website to help you get started with MIPS. Check out the 2019 MIPS 101 Guide, as well as the Skilled Nursing Facility Specialty Measures Set on the CMS QPP website, using the Explore Measures tool, to help you identify relevant MIPS quality measures to report.

For tailored one-on-one assistance, we advise you to reach out to your local Technical Assistance Contractor for free assistance with reporting for the MIPS program. Information on your region’s Technical Assistance Contractor can be found at https://qpp.cms.gov/about/small-underserved-rural-practices.

2. After reviewing our score from last year, cost was something we wanted to improve. We are a specialty office and sometimes we are the only provider a patient may see during the year, so their cost is attributed to our practice. It has been suggested that we encourage patients to also see their primary care physician for a wellness check. Will this help our cost category?

The Total Per Capita Cost (TPCC) measure uses a two-step attribution process to assign accountability for primary care during the performance year. If a beneficiary received any primary care services from a primary care physician (PCP), nurse practitioner (NP), physician assistant (PA), and/or clinician nurse specialist (CNS), then the beneficiary is attributed to the TIN-NPI of the PCP, NP, PA, or CNS that provided more allowed charges for primary care services than any other TIN-NPI. If the beneficiary did not receive any primary care services from a PCP, NP, PA, or CNS, but did receive primary care services from a specialist physician, then the beneficiary is attributed to the TIN-NPI of the specialist physician that provided more allowed charges for primary care services than any other TIN-NPI. If the beneficiary did not receive any primary care services from a PCP, NP, PA, CNS, or specialist physician, then the beneficiary is not attributed to any TIN-NPI. If you are a specialist, encourage your patients see their primary care provider for primary care services, including the annual wellness visit. For more information, see the 2019 MIPS Cost User Guide.

Addendum: In 2020, the TPCC attribution process is changing in some important ways. Attribution will be based on “candidate events” which are identified by the use of certain evaluation and management (E&M) CPT/HCPCS codes, paired with one or more primary care services within a short period of time. The candidate event marks the start of a primary care relationship between a beneficiary and a clinician. Once a candidate event has occurred, the beneficiary will be attributed to the clinician for one year. Certain clinicians are exempt based on specialty. Read more about the changes here.

3. Is it in the best interest of a solo practitioner who does not have an electronic health record (EHR) to submit a hardship exception?

Whether or not you should submit a hardship exception for the Promoting Interoperability performance category depends on your specific situation. If you do not have an Electronic Health Record, applying for a hardship exception is an option you may want to consider, although it does not guarantee a hardship exemption will be granted. Clinicians or groups may submit a Promoting Interoperability Hardship Exception Application, citing one of the following reasons for review and approval:

  • MIPS eligible clinician in a small practice
  • MIPS eligible clinician using decertified EHR technology
  • Insufficient Internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

If you receive a hardship exception for the PI category, the PI category would receive a weight of 0% in calculating your final score, and the 25% weight will be reallocated to the Quality category, making the Quality category worth 70 points. If you qualify, you may also claim exclusions for the PI measures. You can find a detailed overview of the requirements for the 2019 PI category objectives and measures in the 2019 Promoting Interoperability Measure Specifications.

Latest CMS Resources

In recent weeks, CMS has published new resources for small practices participating in MIPS, including fact sheets on the Performance Year 2020 Final Year. See the following links for select highlights of the latest publications.

2020 Final Rule Resources:

 Qualified Registry and Qualified Clinical Data Registry Resources:

APM Resources:

Other Helpful Resources:

To keep up with all the latest resources, check out the Resource Library on the QPP website.

Monthly Observance: World AIDS Day

On Sunday, December 1 we observed annual World AIDS Day. Since the day was first commemorated in 1988, huge advances have been made in HIV prevention and treatment. Nevertheless, according to the CDC, in 2016, 1.1 million people in the United States were living with HIV, and of those, 1 in 7 did not know they had the disease. The purpose of World AIDS day is to raise awareness and support of the year-round work happening in the United States and globally to put an end to the HIV/AIDS epidemic.

This year, the United States launched a new federal initiative titled, Ending the HIV Epidemic: A Plan for America. You can read more about the initiative here. To support efforts and measure performance, MIPS includes 5 Quality Measures focused on HIV prevention and treatment. Read more about these measures below and consider including them in your reporting to improve care and strengthen your MIPS score:

  • HIV Medical Visit Frequency (Quality ID 340): Percentage of patients, regardless of age, with a diagnosis of HIV who had at least one medical visit in each 6-month period of the 24-month measurement period, with a minimum of 60 days between medical visits.
  • HIV Screening (Quality ID 475): Percentage of patients 15-65 years of age who have been tested for HIV within that age range.
  • HIV Viral Load Suppression (Quality ID 338): The percentage of patients, regardless of age, with a diagnosis of HIV with a HIV viral load less than 200 copies/mL at last HIV viral load test during the measurement year.
  • HIV/AIDS: Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis (Quality ID 160): Percentage of patients aged 6 weeks and older with a diagnosis of HIV/AIDS who were prescribed Pneumocystis jiroveci pneumonia (PCP) prophylaxis.
  • HIV/AIDS: Sexually Transmitted Disease Screening for Chlamydia, Gonorrhea, and Syphilis (Quality ID 3205): Percentage of patients aged 13 years and older with a diagnosis of HIV/AIDS for whom chlamydia, gonorrhea, and syphilis screenings were performed at least once since the diagnosis of HIV infection.

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