QPP SURS Newsletter May 2020


  1. Upcoming Events
  2. CMS Extends Medicare Coverage of Telehealth Services
  3. How to Adjust your MIPS Workflow during COVID-19
  4. Small Practice Spotlight: Kali S. Eswaran, Inc.
  5. How to Catch Up on the 2020 Performance Period
  6. Monthly Observance: National Stroke Awareness Month

Upcoming Events

Doctor Talking to Patient


Upcoming Webinar: Understanding How to Implement Telehealth Services: Implications for Solo and Small Group Practices

**No LAN webinars will be held in June 2020. We will notify you of the dates and topic for the July webinar as soon as possible.**

Additional Upcoming Events and Links to Past Events

CMS Extends Medicare Coverage of Telehealth Services

On April 30, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a second round of guidance on Medicare coverage of telehealth services, providing more flexibility for providers and enhanced access to telehealth for patients. The following highlights may be of particular interest for MIPS-eligible providers:

  • CMS is expanding the type of practitioners who can furnish Medicare telehealth services to include physical therapists, occupational therapists, and speech language pathologists.
  • CMS is increasing payments for audio-only telephone visits to match payments for similar office and outpatient visits. Payments for telephone visits will increase from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020.
  • In recognition that many Medicare beneficiaries do not have access to interactive audio-video technology, CMS is waiving the video requirement for certain telephone evaluation and management services and adding them to the list of Medicare telehealth services.
  • CMS is paying for Medicare telehealth services provided by rural health clinics and federally qualified health centers.

For more details, check out the CMS announcement here.

How to Adjust your MIPS Workflow during COVID-19

The 2019 Novel Coronavirus (COVID-19) pandemic has brought new complexities to how clinicians treat and care for their patients. The Centers for Medicare & Medicaid Services (CMS) is focused on providing flexibilities and reducing the burden on clinicians, including through exceptions and extensions to Medicare quality reporting programs, such as the Quality Payment Program (QPP) Merit-based Incentive Payment System (MIPS). Additionally, CMS is helping states increase hospital capacity, expand the healthcare workforce, eliminate paperwork requirements, and promote telehealth. To read the full announcement of these flexibilities, click here.

For solo and small practices continuing to serve your patients during the pandemic, here’s how you can play an important role in addressing this crisis.

1) Transition to telehealth – As many states have implemented social distancing protocols, telehealth is becoming an essential tool in providing health care services to your patient population. CMS has authorized 80 additional services to be furnished to Medicare beneficiaries via telehealth, including emergency department services and home visits. If patients do not have the requisite technology for a Medicare telehealth visit, providers can arrange a Virtual Check-In or e-visit. For more information on telehealth options, see the Medicare Telemedicine Health Care Provider Fact Sheet, as well as the telehealth guidance on the CMS Current Emergencies webpage.

2) Focus on prevention and chronic disease management – As hospitals are being strained with an influx of COVID-19 patients, it’s more important than ever to focus on preventive services and chronic disease management to keep your patients healthy and help prevent potentially avoidable admissions or emergency department visits. By following up with your at-risk patients and those with chronic conditions, you can help reduce potential hospitalizations. For more information on chronic care management, see TMF’s Q&A on Chronic Care Management.  

3) Consider participation in a clinical trial – If applicable, consider reporting on the new COVID-19 Clinical Trials improvement activity (IA_ERP_3), which requires clinicians to attest to participation in a COVID-19 clinical trial utilizing a drug or biological product to treat a patient with a COVID-19 infection, and report their findings through a clinical data repository or clinical data registry for the duration of the study. For more information, see the CMS Dear Clinician Letter.

4) Stay up to date on changing information – In April, CMS updated previously posted guidance, including the Frequently Asked Questions to Assist Medicare Providers and fact sheets on Medicare Coverage and Payment Related to COVID-19. Providers can view telemedicine toolkits, as well as a CMS Dear Clinician Letter outlining expanded options for telehealth services and updates to the QPP. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.

Please stay safe and remember to contact your Technical Assistance Contractor if you need additional assistance during this crisis. TA contractors  provide telehealth implementation guides and workflow tips, webinars, and personalized guidance on how to adjust your MIPS workflow because of COVID-19.  

Small Practice Spotlight: Kali S. Eswaran, Inc.

Kali S. Eswaran, Inc. is a small internal medicine practice in Rancho Cordova, CA. The practice employs three physicians, two physician assistants, and one nurse practitioner. These providers submitted their MIPS data as a group and received a MIPS score of 100 in both 2017 and 2018. Alekhya Alavilli, the practice manager for Kali S. Eswaran, Inc., shared her experience managing the practice’s MIPS reporting and tips for other small practices who want to improve their MIPS score.

  • Create written reminders and tip sheets for providers – Alekhya finds that leaving reminder notes for physicians on patients’ files about necessary exams or screenings is useful in meeting their quality reporting goals. She also shared tip sheets created by her electronic health record (EHR) software to remind providers what steps they need to take to accurately document MIPS measures. Although the practice’s EHR can create automated reminders, she finds that providers often get “pop-up fatigue” and respond better to written reminders.
  • Hold regular staff meetings about MIPS – Alekhya holds meetings with providers every few months to review their MIPS performance. Over time, she has found that the staff have become more receptive to her instructions on collecting MIPS measure data, and everyone pitches in to make sure the practice performs well on their measures and activities, which has contributed to the practice’s exceptional MIPS score.
  • Coordinate MIPS with other reporting requirements – In addition to MIPS, Alekhya’s practice participates in a number of other quality measure reporting efforts. Kali S. Eswaran, Inc. is part of an independent practice association called Sutter Independent Physicians, which reports Healthcare Effectiveness Data and Information Set (HEDIS) measures. For greater efficiency, Alekhya chooses MIPS measures that can also meet the requirements of HEDIS to reduce the burden of reporting different measures to various reporting programs.
  • Careful coding – Alekhya has found that meticulously coding MIPS measures—and careful Hierarchical Condition Category (HCC) coding in particular—is key to her practice’s high MIPS score. The practice’s EHR includes a MIPS dashboard that monitors MIPS measure performance, giving her confidence that her measures are coded accurately. 

Alekhya’s advice for other small practices looking to improve their MIPS score is to start early, educate your entire practice about MIPS, clearly define all reporting responsibilities, and consistently track your MIPS measure performance throughout the year. Alekhya relied on her Technical Assistance Contractor for MIPS educational materials and called them whenever she had any questions about reporting. For free and individualized MIPS support, you can reach out to your TA contractor  by clicking here.

How to Catch Up on the 2020 Performance Period

Now that the 2019 MIPS data submission period has officially ended, here’s what you can do to catch up on the 2020 performance year.

1) Confirm your 2020 MIPS eligibility – Use the QPP Look Up Tool to see if you are eligible for MIPS in 2020. Remember that eligibility can vary each year. If you are ineligible in 2020, you have the option to “opt-in” to MIPS and receive a payment adjustment based on your performance, or you can voluntarily submit MIPS data, but CMS will not apply a payment adjustment. The QPP Look Up Tool also includes preliminary eligibility information for Qualifying Participant (QP) determinations and MIPS Alternative Payment Model (APM) participation for performance year 2020.

2) Start with the Quality performance category – In order to meet data completeness requirements, MIPS participants must collect quality measure data for the entire 12-month performance period (January 1 – December 31, 2020). Small practices will receive 3 points per measure even if they do not meet data completeness requirements. Begin by selecting at least six measures to report (or a complete specialty or sub-specialty measure set) to gain the maximum points in this category. Of these measures, at least one should be an “outcome” measure. If an outcome measure is not applicable to your practice, you must report on at least one high-priority measure. To review a complete list of the 2020 Quality measures, refer to the 2020 MIPS Quality Measures list.

3) Verify changes from last year – Remember that the quality measures you reported in 2019 may not be available in 2020. If you submit your MIPS data via Medicare Part B claims, you should ensure that the coding specifications have not changed since last year. To find out if your quality measures are topped out or no longer eligible to report, review the resources below for your collection type:

4) Start planning your measures and activities for the Promoting Interoperability and Improvement Activity categories – You must report data for both of these performance categories over a continuous 90-day period of your choosing during the performance period. Check out the 2020 Improvement Activities Inventory and the 2020 Promoting Interoperability Measure Specifications to select your measures and activities for this performance period. You can also refer to the CMS Quick Start Guides for Promoting Interoperability and Improvement Activities performance categories to get up to speed on the requirements for these categories.

Remember to reach out to your Technical Assistance Contractor for free support with MIPS. Find your Technical Assistance Contractor here.

Monthly Observance: National Stroke Awareness Month

May is National Stroke Awareness Month. According to the National Institutes of Health, there are over 800,000 strokes every year in the United States, and stroke is one of the leading causes of death in the country. Stroke is also more likely to result in serious long-term disability than any other disease. The Medicare-enrolled population is particularly vulnerable to stroke. Almost 75% of strokes occur in people over the age of 65 and the risk of having a stroke more than doubles each decade after the age of 55.

Strokes happen quickly and require immediate treatment. If you are looking for resources to help educate your patients about their stroke risk, and how to recognize the symptoms of a stroke, you can find information at the National Institute of Neurological Disorders and Stroke website.

MIPS includes several quality measures, listed below, that focus on stroke prevention and treatment. You may want to consider including these measures in your reporting to drive quality improvement and strengthen your MIPS score:

  • Clinical Outcome Post Endovascular Stroke Treatment (Quality ID: 409) – Percentage of patients with a Modified Rankin Scale (mRs) score of 0 to 2 at 90 days following endovascular stroke intervention.
  • Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Quality ID: 226) – Percentage of patients aged 18 years and older who were screened for tobacco use one or more times within 24 months AND who received tobacco cessation intervention if identified as a tobacco user.
  • Door to Puncture Time for Endovascular Stroke Treatment (Quality ID: 413) – Percentage of patients undergoing endovascular stroke treatment who have a door to puncture time of less than two hours. The door to puncture time refers to the length of time it takes for a patient to receive treatment after arrival at a hospital or emergency room.
  • Stroke and Stroke Rehabilitation: Thrombolytic Therapy (Quality ID: 187) – Percentage of patients aged 18 years and older with a diagnosis of acute ischemic stroke who arrive at the hospital within two hours of time last known well and for whom IV t-PA was initiated within three hours of time last known well.

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