MIPS Update During COVID 19

The Centers for Medicare & Medicaid Services (CMS) has released multiple updates to account for the 2019 Novel Coronavirus (COVID-19) pandemic in the Merit-based Incentive Payment System reporting. Information about the COVID-19 is kept fluid and regularly updated by the CMS. MIPS also recommends clinicians to check state and federal health department websites for regular instructions and updates.  So the details below can also serve as merit-based incentive payment system pros and cons.

Second-year performance results are out

We present you with five notes on MIPS payment adjustments and scores from the 2018 performance year which serve as merit-based incentive payment system quality measures:

  • A good percentage of clinicians in MIPS — 98 percent — avoided negative punishment adjustment in 2018. A year before, about 5 percent of clinicians received a negative payment adjustment.
  • Almost 84 percent of clinicians earned an “exceptional performance” position, which resulted in positive payment adjustments ranging from 0.2 percent to 1.68 percent.
  • Some clinicians — 13 percent — received payment adjustments of 0 percent to 0.2 percent.
  • About 356,000 clinicians participated in MIPS through Advanced Alternative Payment Models in 2018, a 15,000 clinician increase from the last year. 
  • About 84 percent of small practices and 97 percent of rural practices earned a positive adjustment in 2018, and almost 74 percent of small practices and 93 percent of rural practices received a positive payment adjustment in 2017.

CMS has introduced guidance for MIPS during COVID-19

The Centers for Medicare and Medicaid Services (CMS) released guidance documents on 2nd July, 2020. The documents provided information on the allowance of telehealth encounters for the Eligible Clinician and Eligible Professional electronic clinical quality measures (eCQMs) used in CMS quality reporting programs for the 2020 and 2021 performance periods. The guidance is directed towards eCQMs used in the including advanced alternative payment model:

  • Medicaid Promoting Interoperability Program for Eligible Professionals
  • Quality Payment Program: The Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs)
  • APM: Primary Care First (PCF)
  • APM: Comprehensive Primary Care Plus (CPC+)

A lot of clinicians were also wondering what is merit based incentive payment system and hopefully their confusion will be cleared by this information. The guidance documents released by the CMS show the telehealth-eligible eCQMs for their particular performance periods. There are 42 telehealth-eligible eCQMs for the year 2020 but only 39 for the 2021. The Centers for Medicare & Medicaid Services (CMS) explains that where an encounter can be included in an eCQM if it is identified with a telehealth-eligible code regardless of whether the encounter was provides via telehealth or in-person unless otherwise indicated by CMS in the eCWM definition statements or in the guidance. 

CMS also informs that there may be some instances when quality action can’t be executed during the telehealth encounter and states, “it is the eligible professionals’ and eligible clinicians’ responsibility to make sure they can meet all other aspects of the quality action within the measure specification, including other quality actions that cannot be completed by telehealth.”

Medicaid Promoting Interoperability Program for Eligible Professionals

The Centers for Medicare & Medicaid Services (CMS) has taken multiple measures to promote interoperability programs for eligible professionals during COVID-19. Here’s what you need to know:

  • CMS allows medical professionals who have been rattled by the coronavirus pandemic to submit an Extreme & Uncontrollable Circumstances Application. If approved by the authorities, they will reconsider MIPS performance categories for 2020.
  • Clinicians must be able to show how their practice has been affected by the pandemic for payment adjustment based on the merit-based incentive payment system.
  • According to the American College of Cardiology’s summary of the rule changes, CMS will not be using data from the first six months of this year to calculate any of its quality metrics for 2020.  
  • Participating COVID-19 clinical trials can earn MIPS-eligible professionals 20 points as reminded by ACC. Members need 40 points to get the maximum score in the MIPS Improve Activities category.

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