Is your practice trying to maximize its Merit-Based Incentive Payment System (MIPS) payment adjustment in 2019 by reporting all required measures in 2017? If so, keep reading – or forward this to your practice manager. For those of you looking to simply avoid a penalty in 2019, you can do so by reporting one quality measure or one improvement activity in 2017 (no need to worry this year about the benchmarks detailed below). Read last week’s Advocacy Insider article for details on how to avoid a penalty.
A focus on quality measures
CMS recently released the quality measures specifications and performance benchmarks that determine how your practice’s Quality category will be scored. In 2017, the Quality category represents 60% of your total MIPS score, so performing well on Quality is essential if you are looking to maximize your payment adjustment.
To maximize your quality score in 2017, you need to report six quality measures (or one specialty set) for a minimum of 90 consecutive days. One of the six measures must be an outcome measure (or high-priority if none available). You can also receive bonus points for reporting additional outcome or high-priority measures and for reporting all quality measures electronically. There are several options for reporting quality measures:
- EHR Direct
- Qualified Registry
- Qualified Clinical Data Registry (QCDR)
- Web Interface (for groups of 25+ only)
Under the old Physician Quality Reporting System (PQRS), you simply had to report quality measures, but your performance on those measures didn’t matter. Now, however, the game has changed; each quality measure is assessed against a benchmark to determine how many points the measure earns. You can receive anywhere from three to 10 points for each measure.
We suggest you review the performance benchmarks carefully to select the measures that will maximize your performance score. Some measure benchmarks are “topped out,” which means there is historically little variability in performance. It is more difficult to get top scores for these measures (in 2017, a quality score of 100% is required to get the full 10 points), so you may want to consider alternative measures.
Another set of measures (those without actual performance data submitted to PQRS in 2015) have no benchmark at all. CMS will attempt to calculate benchmarks based on 2017 performance data; benchmarks will be created if there are at least 20 reporting clinicians or groups that meet the criteria for contributing to the benchmark. If no benchmark can be calculated, however, the measure will receive only three points. Since it is impossible to predict whether a benchmark will be calculated for these measures, or what those benchmarks will be, you are essentially flying blind if you choose to report one of these measures.
To complicate things even more, CMS created different benchmarks for different submission types (EHRs, registries and claims).
The bar is highest for those reporting via claims. Of the 56 claims measures with a benchmark, only five can get the full 10 points without scoring 100%. It will be very difficult for allergists to achieve a top quality score by reporting via claims.
There are more measures with benchmarks for those reporting via Qualified Registry or QCDR – 118 in total. However, only 24 can get the maximum 10 points without scoring 100%.
Reporting via EHR Direct may provide more options for maximizing your quality score. There are only 44 measures with a benchmark, but 34 of them can get the maximum 10 points without a score of 100%.
|Submission Type||Total Available Measures||Measures with Benchmark||Measures with benchmark that can get a top score without 100% performance|
* This measure count may not include specialty measures developed for individual QCDRs
In short, the reporting method and quality measures you choose both matter. To maximize your quality score in 2017, and to position yourself for a maximum payment adjustment in 2019, take the following steps:
- Review your reporting options. If possible, choose to report via EHR Direct, Qualified Registry or QCDR.
- If you participated in PQRS in 2015, review your 2015 Quality and Resource Use Report (QRUR), which shows how you performed on quality and cost measures. Exhibit 3 will give details on your quality measure performance, and can help you select good measures to report in 2017 – or show where you need to improve.
- Review the performance benchmarks carefully. Select quality measures that meet the following criteria:
- They are realistic for your practice. Use your QRUR as a guide, if applicable, and check the 2017 quality measures specifications for measure requirements.
- They are not “topped out” – and don’t require 100% performance to get the full 10 points. If you do choose a “topped out” measure, make sure you can get 100% performance.
- They have a defined benchmark.
The College will continue to provide the MIPS information you need. Keep checking Advocacy Insider for updates.