Quality Changes

The Quality performance category of MIPS has a few new twists in participation year 2019. This year the weight of the category is 45 percent down from 50 percent the previous year. Six bonus points will be added to the numerator of the Quality performance category for MIPS eligible clinicians in small practices (15 or fewer clinicians) who submit data on at least one quality measure.

If you are a clinician that submits eCQM data collected by certified EHR technology (CEHRT), you must have 2015 Edition CEHRT in place by December 31, 2019 and the 2015 CEHRT must be used to generate your eCQM data for reporting. Perhaps the biggest change in 2019 is only physicians that have small practice designations can report quality data via Medicare Part B claims. This means larger groups will need to find another collection and submission type in order to submit quality data.

Small practices will also have the opportunity to report quality as a group via claims-based reporting. Whether you choose to report as an individual or group for MIPS, it does not affect the type of NPI information that you submit on your claim form for Medicare Part B claims measures. Finally, physicians can report quality data using more than one submission type. This means if you are only able to submit three Medicare Part B claims measures, you can meet the requirements by submitting data for three eCQMs (EHR), three MIPS CQMs (Registry), etc. as long as at least one outcome measure or high-priority measure is submitted among the six total measures.

2019 Quality Benchmarks

Quality benchmarks for the MIPS CQMs, Qualified Clinical Data Registry (QCDR) Measures, Medicare Part B claims measures, and eCQMs collection types are established using historical data that’s collected two years before the performance period. The 2019 Quality benchmarks were established using 2017 MIPS performance data and are broken down into “deciles,” with each decile having a value between three and 10 points.

There is a three-point floor for measures that can be reliably scored based on performance. Once measures are submitted, CMS compares your performance on a quality measure to the performance levels in the national deciles. The points you earn are based on the decile range that matches your performance level.

Remember, to be scored on a national benchmark, two conditions must be met. Data completeness criteria has to be reached, meaning at least 60 percent of possible data is submitted, and sufficient case volume has to be met, which is greater than 20 cases for most measures. Please click the link below to access the 2019 quality benchmarks.

2019 Quality Benchmark File

Quality Bonus

For the 2019 performance period, CMS continues to provide opportunities to earn improvement points. Physicians can earn up to 10 percentage points based on the rate of improvement in the Quality performance category against the year before. These bonus points will be incorporated into you or your group’s/virtual group’s overall Quality performance category score.

Bonus points are also available for submitting additional measures including one bonus point for each additional high priority measure, and two bonus points for each additional outcome and patient experience measure. Lastly, the end-to-end electronic reporting bonus is still available this year for those physicians reporting quality directly from certified EHR technology (CEHRT). One bonus point per measure is available and capped at 10% of the Quality performance category denominator.

Quality Requirements

Many requirements for the Quality performance category are staying the same this year. The performance period is again a full calendar year (January 1 – December 31, 2019). In order to fulfill the full category requirements eligible clinicians will want to submit six quality measures (or at least six measures within a specialty measure set, unless the set contains fewer measures) for that 12-month performance period.

Among the six quality measures submitted, clinicians must include at least one outcome measure. If there isn’t an applicable outcome measure then a high priority measure must be reported instead. If you submit your quality data through claims or a qualified registry, and you submit less than the six required quality measures, CMS will use the Eligibility Measure Applicability (EMA) process to see if there are clinically related measures you could have submitted and adjust the scoring accordingly.

by Daniel Day | Quality Improvement Advisor