MIPS changes impacting 2020

CMS has analyzed cost data for the 2020 performance year. Based on their findings, CMS announced on 5/21/22 that the Cost Category will be reweighted. This could definitely impact your payment adjustment in 2022!

Reasons include:

  • significantly reduced utilization, 

  • impact of hospitalizations related to COVID 19, and 

  • decreased number of providers and practices meeting the minimum thresholds for the cost measures

What does this mean for you? 

Your final MIPS score for 2020 will be adjusted as follows for Individuals/Groups reporting:

  • All categories

    • Quality = 55%

    • Improvement Activities (IA) = 15% 

    • Promoting Interoperability (PI) = 30%

  • Quality and Improvement Activities (IA)

    • Quality = 85%

    • IA = 15%

  • Improvement Activities (IA) and Promoting Interoperability (PI)

    • IA = 15%

    • PI = 85%

  • Quality and Promoting Interoperability (PI)

    • Quality = 70%

    • PI = 30%

This adjustment will be automatically applied by CMS, so you do not need to do anything other than be aware.

2020 MIPS Relief for COVID

The News We Have Been Waiting For!

CMS Announces Relief for 2020 QPP (MIPS) Participants in Response to the COVID19 Pandemic

As we continue to manage the impact of the COVID19 pandemic, CMS is now offering flexible reporting options for 2020 QPP/ MIPS participants.

What you need to know:
Any clinician significantly impacted by COVID19, can submit an Extreme & Uncontrollable Circumstances Application to CMS.
Application Deadline: December 31, 2020 at 8 p.m. ET.
*QPP log in will be required to submit application.
https://qpp.cms.gov/mips/exception-applications#extremeCircumstancesException-2020

Circumstances Covered:

  • Public health emergency (COVID19).

  • Inability to collect information needed to report for MIPS successfully.

  • Unable to collect sufficient data due to office closings.

  • Performance has been impacted due to new workflows implemented such as using Telehealth services to provide patient care outside of the office setting.

What does it mean?
You can apply for a complete exception for all 4 categories, no attestation required.
You can continue to attest / submit using your best performance categories and the remaining categories will be re-weighted. For example, the categories that were harder to achieve due to the pandemic.
 
Performance categories include:

  1. Quality

  2. Cost

  3. Improvement Activity

  4. Promoting Interoperability

Complete Exception:
Submit application for all 4 categories to be re-weighted - Application Approved.
All categories are re-weighted to 0% > Neutral adjustment > No incentive, no penalty.

Reweigh Selected Categories:
Submit data for 2 or more categories, other categories are re-weighted to 0% based on application.
Submission of 2 or more categories allow for possible positive incentive.
> Final score will be based on category data sent.
> Possible positive incentive, no penalty.

Adjustment Examples:

Approvals/ DenialsCMS will send an email with approval or denial after the application/ circumstances have been reviewed. If approved, submission would not be necessary for the categories requested in application.eHealth is here to help and answer a…

Approvals/ Denials

CMS will send an email with approval or denial after the application/ circumstances have been reviewed. If approved, submission would not be necessary for the categories requested in application.

eHealth is here to help and answer any additional question you have. We still encourage everyone to submit if your score is over 85 as it qualifies you as an “Exceptional Performer.” The possibility of receiving a positive incentive is still available, any little bit helps during these trying times.

Appropriate Use Criteria

After upgrading to Professional EHR 19.4, Radiology Decision Support can be activated to prompt providers at the point of care, allowing them to review the appropriateness of the diagnostic imaging test they have ordered based on the diagnosis. But how does this really work? How do you communicate this information with the Practice Management system so the correct information is on the claim?

Setup is required in EHR and PM for billing. In EHR and PM, you must:

  1. Add or activate the G code. G1004 reflects that a Clinical Decision Support Mechanism National Decision Support Company, as defined by the Medicare Appropriate Use Criteria Program, aka, CDSM NDSC, CareSelect, was used to determine the appropriateness of the diagnostic test.

  2. Add the following modifiers

  •        ME – The order adheres to the criteria.

  •       MF – The order does not adhere to the criteria.

  •       MG – The order does not have any criteria in the CDSM.

  •       MA – An emergency medical condition.

  •       MB – Insufficient internet access.

  •        MC – EHR or CDSM vendor issues.

  •       MD – Extreme or uncontrollable circumstances.

  •       MH – It is unknown if a consultation was performed.

Once set up is complete, providers or clinical staff on the provider’s behalf document in the EHR.

  1. Place the diagnosis and diagnostic procedure in Assessment and Plan.

  2. Attach the correct modifier to the diagnostic procedure.

  3. Include the G code in the encounter if modifier ME, MF, or MG are attached.

  4. Remember that the diagnostic imaging code and the G code must be billable to cross the interface.

eHealth has a workflow for this and can assist you with setup if needed. Please let us know if you need assistance to create an efficient workflow for your practice.

Schedule your upgrade – remember, you must be on 19.4 or higher before December 2020 to continue to ePrescribe. The upgrade schedule at Allscripts is filling up so you need to go ahead and schedule.

This upgrade requires planning. It can be quite a shock to users because of the different colors and icons – a completely different user interface. We have several dates on the calendar for Implementing Pro EHR 19.4. Have an upgrade party in the conference room and make the most of this class!

Mid-Year MIPS Updates

Preliminary Feedback Reports for 2019

  • Log into the QPP website to access your preliminary feedback reports.

MIPS Updates image.docx.png

  • A screen will display reminding you that the data is preliminary and will be finalized later in the summer of 2020 (July). When the reports are finalized, you will be able to submit a Targeted Review if needed. You must agree to continue.

  • Click on Download Data to access the Submission Data that CMS received from you either through manual entry, submission by your EHR, or submission through a third-party vendor. The Connected Clinicians included in the report are also available here.

  • Click on View Practice Details to go to your Performance Feedback Report.

MIPS Updates image2.png

MIPS in 2020

At this time, 2020 has not been designated as a year of Extreme and Uncontrollable Circumstances (EUC) by CMS. I anticipate that this will happen, and when it does, you still need to evaluate whether it is in your best interest to apply for an exception or continue to submit data as you normally would. You may be able to do both, apply for the exception and then depending on how your data looks, go ahead and submit in the beginning of 2021. Typically, submission trumps an exception application and we will keep an eye out for this as the year unfolds and CMS issues guidance.

The payment adjustment in 2022, for the 2020 performance year, is set at +/- 9%, maintaining budget neutrality. This means positive adjustments may be lower than expected but are still positive! Here is the breakdown:

Approved EUC Application = Neutral adjustment

Final Score above 45 pts = Positive Adjustment between 0 – 9% (adjusted to remain budget neutral)

Exceptional Performer (> 85 pts) = Positive Adjustment 9% (adjusted to remain budget neutral) + a percentage of the $500 million set aside for exceptional performers

We are happy to assist you with monitoring your MIPS data and/or making decisions for your 2020 submission. Just let us know!

New Improvement Activity

Due to the Public Health Emergency, a new Improvement Activity has been added - (IA_ERP_3) COVID-19 Clinical Trials Improvement Activity.

To use this high priority measure, you must be able to attest that you are participating 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 their study.

Reporting of this data would also meet the requirements for one of you Public Health Measures in the Promoting Interoperability category.

eHealth Checking In

How are your Telehealth visits coming along? What percentage of your visit count have you been able to replace so that you are not continuing to lose revenue?

eHealth has assisted many practices with setting up, training, and implementing Telehealth successfully. We also included marketing Telehealth services to patients in order to increase uptake and educate patients up front on what to expect and how to connect.

I did a Lunch and Learn for 4Med Plus on Wednesday and there were a lot of great questions around providing and billing Telehealth Services. For example, have you considered providing Annual Wellness Visits and Transitional Care Management Visits through Telehealth? We will be providing a class on conducting the Annual Wellness Visit through Telehealth on May 8th.

Have you implemented Chronic Care and/or Principal Care Management?

This is a great way to make sure you continue to provide excellent care for the chronically ill. Patients over the age of 65 need to stay home more than any other part of the population. Staying connected with them is extremely important to keep them healthy, both mentally and physically. We can quickly help you ramp up and start taking advantage of one of these programs immediately!

Have you received your relief payment from the second wave of the CARES Act?

You may need to take action in order to receive this money. Click Here for an informative article on the topic from Part B News or go directly to the HHS website.

What do you mean we have to upgrade in the midst of this?

Yes, it is true. All clients must be on a version of 19.x by December 1, 2020 due to changes with ePrescribe requirements. You have probably already received a letter from Allscripts. eHealth can assist you with this. We have had 19.1 on our training server for some time now. We are prepared to provide remote training for your staff. You can save a lot of money by letting us teach you versus weeding through the Release Notes to identify new functionality and the best way to use it in your practice. We have done the work, so you can just take advantage of the results! We even have practical eHealth Release Notes that we can share. Stay tuned for implementation classes coming up in May!

Is your waiting room empty? Take action to protect revenue!

As a health care community, we are not only struggling to care for the patients with symptoms of COVID-19, we are also faced with the fight to keep our practices alive and healthy in order to continue to provide care in the future. Let’s explore some things you can do today!

  1. Fill up your Virtual Waiting Room

    1. Implement or expand Telehealth in you practice.

    2. Verify your malpractice insurance requirements.

    3. Know that the majority of insurance companies reimburse at the same rate as face to face, but you must check your carriers.

    4. Learn the new codes covered by Medicare. 80 new codes were approved this week including physical, occupational, and speech therapy services, expanded psych/neuropsych services, and expanded ESRD services.

    5. Make sure the Practice Management and EHR are set up to work accurately and efficiently and that staff are trained on a solid workflow (this is where eHealth can assist you in being live a few days after you make the decision – we have lots of experience).

    6. Choose a vendor that is right for your practice. We have experience and can assist with this decision. Telehealth will persist after COVID-19 so choose a vendor that will be HIPAA compliant, so you won’t have to change later on.

    7. Market the new program with your patient population! Use the reporting Module to send web messages. Use a third-party email system after exporting your patients (with or without web accounts) and their emails. eHealth can assist you here as well.

  2. Take advantage of the time to try something new through Telehealth.

    1. Transitional Care Management

    2. Chronic Care Management (CMM) can be provided by primary care and specialist practice. eHealth has an excellent workflow for this, and we would love to help you get started. You do not have to outsource CCM!

    3. Did you provide and/or train someone on use of a device recently? Have you considered implementing Remote Patient Monitoring?

    4. Substance Abuse Counseling

    5. Medicare Annual Wellness visits

    6. Learn more about the Reporting Module and how it can work for you now more than ever. Contact eHealth if you are interested in a class.

  3. Are you spending time filling out the CDC Person Under Investigation Form? This burden is estimated at 30 minutes per patient by CDC. Form Builder can reduce this time a bit, but building a Procedure Entry Rule template that is integrated with an Output Manager document is the most efficient workflow and is a significant time saver for you. eHealth can provide this service to help your providers in completing this form quickly as the virus numbers continue to rise.

  4. Consider applying for Accelerated Payments from Medicare if you need additional revenue assistance. Learn more here.

Our mission at eHealth is to support you in providing the best, most efficient care possible to your patients using the tools you have at hand and recommending additional tools that make financial sense. At eHealth, we are an extension of your team and pride ourselves in covering our own cost through the value we provide your practice.

Rethinking Care Amid the Coronavirus Pandemic

As the United States responds to the outbreak of Coronavirus, physician practices are forced to rethink ways to continue to provide care to patients who are no longer comfortable coming to the office. The strong recommendation to postpone routine visits to the doctor and avoid spending time with other sick individuals in the waiting room could pose other issues due to missed monitoring of chronic disease patients and delays of preventive health care.

The solution to continuing to provide care for these patients is Telehealth. It is easy to implement, and the reimbursement is the same as an in office visit if billed and documented correctly. In addition, Medicare has waived the originating site definition to make it safer for patients at high risk for COVID-19 as well as those with symptoms of COVID-19 patients to continue to receive care.

Quick facts to start Telehealth:

  1. Identify who will provide Telehealth services, what types of visits you will offer via Telehealth, and when Telehealth services will be available.

  2. Set up your Practice Management system for Telehealth. This may include creating a new location, visit type, schedule, etc.

  3. Customize your EHR to make documentation efficient for Telehealth visits. Remember consent and education about the patients co-pay must be addressed at the beginning of each visit and documented.

  4. Choose a Telehealth vendor that supports HIPAA compliant audio and video communications. This could be through your EHR vendor or a 3rd party vendor.

eHealth has already assisted clients with implementing Telehealth solutions. We are happy to assist you with customization in EHR and/or PM either through your current contract for services or through our virtual meetings service. We have also customized client systems to make documentation of the COVID-19 evaluation efficient through the addition of a new Reason for Visit, adding labs to the lab catalog,  short list creation, as well as adding the CDC form for patients with COVID-19.

MIPS 2020 --- What You Need to Know

What happens if I don’t participate in MIPS?

If you exceed the low volume threshold and do not participate, a - 9% adjustment will be applied to your Medicare Fee-for-Service(FFS) reimbursement in 2022. This is easy to avoid with minimum effort on your part. You just need some guidance to get you there.

Why should I opt in to participate?

Every practice is already doing the work, so it makes sense that you would capitalize on the extra revenue. Depending on how well you do, you could even receive part of the $500 million that is still available for disbursement.

Accuracy is an imperative piece of quality reporting. If your current Quality or Promoting Interoperability reports are not reflecting your high level of performance, you should contact eHealth about custom reporting. We combine the specifications with your individual practice workflow to reflect your high level of performance.

How do I know I am eligible for MIPS?

Check the Quality Payment Program Eligibility Page. This page is integrated with PECOS. When you enter your NPI, youI will get a report of all of the Tax ID numbers (TIN) that the NPI is actively associated with and whether or not the eligible clinician is able to participate as an individual clinician or group, or is perhaps part of an Advanced Payment Model (APM).

I like to think of eligibility as a two-step process. First, is the clinician in the list of eligible clinicians?. Second, did that clinician meet the low volume threshold as an individual or group?.

What is the difference between participating as an individual versus a group?

First, a group is defined as two or more eligible clinicians under the same TIN that have reassigned their billing rights over to the TIN. There is a virtual group definition as well, but it is hardly worth mentioning since so few practices are participating through this method.

There are several reasons I can think of for participating as a group versus an individual, but the most important is that it opens the door for all eligible clinicians in the group to receive the positive payment adjustment, even if they do not meet the low volume threshold individually. I am all about an opportunity to increase revenue for the practice!

Choosing to participate as a group also means that data from all eligible clinicians, regardless of whether they meet the low volume requirements or not, must be included in the aggregated scores for all the MIPS categories the group submits.

MIPS Scoring Thresholds

Threshold to avoid a negative payment adjustment = 45

Threshold for Exceptional Performer Status = 85

2019 Submission To Do List

What are the MIPS Scoring thresholds for 2020?

Final Score = 45

Exceptional Performer = 80

What happens if I don’t participate in MIPS?

The 2020 performance year of MIPS determines whether or not a +/- 9% adjustment will be applied to my Medicare FFS reimbursement in 2022. Being in private practice, making sure I get the highest payments I can for services is very important for my business, especially if all I have to do is provide care as I normally would and just track a few things to send in at the beginning of 2021. Depending on how well I do, I can also receive part of the $500 million that is still available for disbursement.

How do I know I am eligible?

I check the Quality Payment Program eligibility page. This page is integrated with PECOS and when I enter my NPI, I get a report of all Tax ID numbers (TIN) my NPI is actively associated with and whether or not I am eligible to participate as an individual clinician and/or group.

 I like to think of eligibility as a two-step process. First, are the clinicians in my group included on the list of eligible clinicians. Second, do the clinicians meet the low volume threshold for participation.

MIPS Eligible Clinicians

*Represents newly added eligible clinicians in the past 2 years

*Represents newly added eligible clinicians in the past 2 years

The low volume threshold is a determination based on a two year look back period to see if I have billed more than $90,000 in Medicare Fee for Services, billed for more than 200 Medicare services, or provided care to more than 200 Medicare beneficiaries. If I meet all three parts of the definition, I am required to participate. If I meet 1 out of the three, I can opt in. If I don’t meet any, I could voluntarily report data.

 What is the difference between participating as an individual versus a group?

First, a group is defined as two or more eligible clinicians under the same TIN that have reassigned their billing rights over to the TIN. There is a virtual group definition as well, but I am not going to address that today because there is very little participation in this model.

There are several reasons I can think of for participating as a group versus an individual, but the most important is that it opens the door for all eligible clinicians in the group to receive the positive payment adjustment even if they do not meet the low volume threshold individually. I am all about an opportunity to increase revenue for the practice!

 Choosing to participate as a group also means that data from all eligible clinicians, regardless of whether they meet the low volume requirements or not, is considered/must be included for all the MIPS categories the group submits.

2020 ICD 10 Code Updates

Just a quick reminder if your server is on site, you need to update your Diagnosis Codes reference files. You do this by downloading the new data from Client Connect and then importing that information into the PM system.

Here are the instructions: https://documentation.allscripts.com/bundle/bar1372422257408__bar1372422257408/page/bar1355339279552.html

  1. Access the download by logging into Client Connect, click on Downloads and Select Allscripts Practice Management.

  2. Choose the version of Allscripts PM you are on and download the file into the folders you created per the instructions.

PM 2020 Code Update-blogimg.png

CPT Codes will be published for January implementation. We are working on a process to automate the CPT update. Stay tuned for additional information.

Promoting Interoperability

Supporting the Electronic Referral Loop by Sending Summary of Care Information

Does your denominator seem lower than it should be for this measure? Does it look like your group or individual clinicians are excluded when you know more than 100 referrals have been ordered for your patients during the 90+ day reporting period? We have been seeing this trend with our clients.

We learned from Allscripts yesterday that the eligible clinician is required to sign off on the encounter in order for a referral to count in their denominator. It does not matter if ancillary staff order the referral on behalf of the clinician, if that clinician does not personally sign off the encounter, their denominator will not increment. As a result, you may appear excluded when you actually are not.

We also asked CMS and received the following Q/A response:

Q: If a referral is ordered on behalf of a provider by a member of the provider's staff, does that count as a referral? (i.e., the provider has instructed the staff member to send health information, but has not signed off on it directly)

A: The denominator includes the number of transitions of care and referrals during the performance period for which the MIPS eligible clinician was the transferring or referring clinician. This includes referrals within the group.

As long as the CEHRT is reflected under the eligible clinician's NPI, CMS does not dictate the internal workflow used by a MIPS eligible clinician. Therefore, if your internal policy allows for other staff to perform functions related to referrals under the MIPS eligible clinician's NPI, it is a viable option.

What should you do?

  1. Evaluate your workflow to see if you need to make the change and require your clinicians to sign off on all referrals.

  2. Make sure you export at least one Summary of Care document, even if you are excluded, so that in the case of an audit you do not risk losing all of your Promoting Interoperability points.

  3. Take ACTION – the last 90 day reporting period begins in October!

Other options:

If you are a server onsite client, eHealth does offer custom report options based on your CEHRT. If you would like us to assist you with a report that is in line with CMS’ description of the specification for this measure, please contact us here.

Custom Reports Are Essential to Your Revenue

Custom Reports Are Essential to Your Revenue, Here’s Why

The decision to use custom reports provides a significant financial return, not only by increasing the positive payment adjustment that you receive for each PFS service, but also by decreasing the man hours needed to continuously audit inaccurate reports. eHealth has written the Promoting Interoperability reports as well as many of the Clinical Quality Measure reports to provide you with accurate performance data based on your workflow. We make sure to adhere to the specification documents and the regulatory guidance in development and implementation of our reports while giving you the ability to follow a natural workflow that fits your practice.

Pricing starts at $1500.00 for the first Promoting Interoperability report and additional PI reports are $1200.00 OR you can purchase the entire PI package for $4800.00 – that’s a $300 savings! Many of our clients that have a server on site are using these reports so they can accurately report to CMS and ultimately receive a higher MIPS payment adjustment. We have MIPS reports, HEDIS reports, and financial productivity reports that pull data from both your EHR and PM systems into consolidated reports. Let us know what you need for your quality programs and we will assist you!

A Testament From One of Our Specialty Practice Clients

"I absolutely think participating in MIPS is worthwhile. Our positive payment adjustment will likely be higher in 2020 based on our 2018 score, especially as the thresholds get higher and fewer practices meet the exceptional performance threshold. I think it’s easy to look at the “pick your pace” solution CMS came up with and feel like it’s not that much money on the line, but long-term, it is. A potential 9% loss in revenue is significant, and that goes on year after year. I know that most small practices, especially family practices, don’t have the resources to devote to this program, but with the potential loss in revenue in future years, I don’t think those smaller practices can afford not to devote some time to it. Their margins are typically really tight as it is and losing 9% of their Medicare revenue isn’t something most small practices can afford to do. It doesn’t have to take a large cash investment to participate; most EMRs have something built in to track the required measures. It also doesn’t have to take a full-time employee to do the work. I certainly don’t spend even half of my time working on MIPS, probably even less than a quarter of my total time, if we look at the whole year. Of course, I have your team helping me with the heavy lifting!"

-From Maria Eddings, Clinical Analyst at Renal Care Consultants

2019 Q & A

Several repetitive questions have come up recently, so we have compiled them here for the benefit of everyone.

Q:  What do I need to participate in MIPS this year?

A:  With Allscripts, you need the 2015 CEHRT package and you need to be onPro EHR version 17.1.x or newer. All other services are optional and here is what they represent, per Allscripts sales descriptions and the presentation provided by Allscripts on 1/17/2019:

MIPS Reporting: This is a subscription $359. per provider that gives access to a dashboard that includes Quality, Cost, Improvement, and Promoting Interoperability. It also includes clinician ranking, data submission tools, and your estimated MIPS score. There may be other services associated with this program that are not listed here. I do know that if you choose to use EHR submission, you are limited to the EHR measures. This is very limiting if you are a specialist. It is very easy to submit using a registry, so I would encourage you to explore this if you are a specialty practice or multi-specialty. The registry we use charges $100./ provider for submission of quality, improvement, and promoting interoperability.

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Success Monitoring Program: The Success Monitoring is a program where a Service Analyst is assigned to the client and will review their reports.  Depending on which Monitoring Package you select determines the level of review. This is a minimum of a $5000. line item.
*Comparably, eHealth’s QPP Monitoring Program is $3500.

Professional MIPS Services: This package includes consulting services for MIPS.

Q:  Electronic Prescribing of Controlled Substances – what is needed for the upcoming vendor change?

A:  Allscripts is changing to an easier identity proofing provider late next week. You should receive documentation related to this change in vendors; however, I did want to make sure you know that everyone will need to re-enroll in order for their EPCS privileges to work. Allscripts is projecting  an effective date of 3/21/2019 for this change.

Q:  What is the deadline for submitting data to CMS for 2018?

A:  April 2, 2019 at 8 PM EST

Q: Am I limited to one method of submission for Quality Measures in 2019?

A:  No, you can use multiple methods. This is especially important if you are a specialty practice and are interested in participating in measures that cannot be submitted via the EHR. You could use claims, registry, and EHR to cover the quality measures you would like to track for 2019.

Q:  Do I have to use the numbers generated by my EHR for the Quality and/or Promoting Interoperability reports?

A:  The short answer is No. Here are some things to be mindful of – you do need to use a vendor that adheres to the specifications based on your Submission Type (registry, QCDR, claims registry), you also want to use your CEHRT to document the clinical information related to the measure specification. If this is something you are interested in, please ask for additional information. It takes more than just a few sentences to make sure you have a compliant plan for your numbers. Remember – ACCURACY DIRECTLY EFFECTS YOUR BOTTOM LINE!

To dos prior to 2018 submission

To dos prior to 2018 submission

  1. Know your deadline: you can submit up until April 2, 2019, 8 pm EDT

  2. Validate the information on file in the PECOS system:

    • Make sure that the NPIs affiliated with your Tax ID Number are current.

    • Verify your financial information to  ensure your bank and account numbers are correct. This can hold up your payment.

  3. Think about whether you meet the Data Completeness definition for your 2018 data

    • Data completeness means that you are reporting on a high percentage of the patients that meet the denominator criteria. This is currently set at 60% for 2018.

    • If you have lots of charts for which the billing level has not been assigned, typically unsigned encounters, then these patients and their clinical data may not be pulled in the ETL and may not be included in your AAP reports. This impacts your data completeness.

  4. Save all supporting data in a secure location, this could be electronically or on paper.

    • Quality reports including the initial patient population (IPP), denominator, numerator, exclusion, and exception numbers.

    • Your performance feedback report for 2017.

    • Supporting documentation of your Improvement Activities.

    • Your Security Risk Assessment from the 2018 calendar year.

    • Reports reflecting your Promoting Interoperability measures, including evidence of Active Engagement with public health registries.

MIPS in 2019

If you are using Allscripts Professional EHR, you will need different things dependent upon the method of submission you choose.

  • EHR Submission – You need both the 2015 certification package and the MIPS reporting package

  • Registry Submission – You need only the 2015 certification package

  • ACO Submission – You need only the 2015 certification package

  • QRDA upload to CMS website – You need both the 2015 certification package and the MIPS reporting package

Here is the difference based on what we have learned from Allscripts:

  • The 2015 CEHRT package provides all needed elements to attest that you are using a 2015 CEHRT EHR. It also gives you access to your Quality and PI reports through AAP. If you are part of the Quality Payment Monitoring program and submitting through the registry, this is all you need.

  • The 2015 MIPS package provides the 2015 CEHRT package in addition to the ability to view your dashboard, create QRDA files, and have access to Allscripts services and submission on your behalf.

Security Profiles

Security profiles must be set up for the following functions to work:

  • Prescription Price Transparency: All providers must set up their security profile in order to activate the use of prescription prices. Clinical staff assigned as prescriber agents will automatically have access to prescription prices due to providers’ enrollment and have no need to create individual

  • Images Clinical Application: All users (clinical/providers) that will need to take images using the Images application (on tablets only) will need to set up security profile.

  • Info Button Patient Education: All users (clinical/providers) that need to access patient education in Assessment & Plan need to set up a security profile.

Security profiles need to be set up by each individual user and require an email address. Please follow the instructions below:

Security Profile Set Up Instructions

1. In the Clinical Module, click on ‘Menu’

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2. Enter your email address

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3. Click on ‘Yes’ to create a new security account

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4. Enter your existing Clinical Module password

5. Create a new password for your security account (it cannot be the same as your Clinical Module password)

6. Click OK

Checklist for 2018 Wrap Up

QPP Website

  • Validate the eligibility for NPIs associated with your practice

    • Remember to note any other TINs that NPI is associated with

    • If you are part of an ACO, check for QP designation

  • Review the Physician Compare Report that will be posted early in 2019

    • If anything is incorrect, you need to report it as soon as possible to prevent it being posted publicly

Prepare for Submission

Know your numbers

Quality

  • Pull your data together at the individual and/or group level

  • At the end of the year, make sure you save copies of supporting data for the final numbers you approve for submission to CMS

Cost

  • Your performance for the cost measures are listed on the Performance Feedback Report

  • Know your numbers and how they impact your final score

  • There isn’t any supporting documentation to save in this category

  • AAPM participants are already meeting this category and nothing additional is required

Improvement Activities

  • Identify which Improvement Activities one or more providers actively participated in during 2018

  • Save the list of activities as well as any report documentation that tracks your participation and progress related to each activity.

  • AAPM, ACO, and PCMH participants are already meeting this category and nothing additional is required.

Promoting Interoperability

  • Pull your data together at the individual and/or group level

  • You must complete the Security Risk Assessment update in the 2018 calendar year. Let us know if you need help ASAP!

  • You must perform at least one event in each of the base measures to get any points in this category. Base participation completion = 50 points plus any additional points you receive from performance and bonus points.

  • At the end of the year, make sure you save copies of supporting report data for the final numbers you approve for submission to CMS.

Choose a Submission Method

EHR

  • You may already be signed up with your vendor to submit your data. This needs to happen prior to the deadline of March 31, 2019. Make sure you have a meeting to approve the data being submitted on your behalf!

Registry

  • If you are submitting via an approved Registry or QRDA, you should already have a contract in place and know what to expect. If you don’t, you will want to act on that pretty quickly.

  • You are still able to get the end-to-end submission bonus with some registries.

  • Registries give you access to MANY measure choices that you don’t have with other submission methods.

CMS Web Interface

  • If you have not already registered for this method of submission, it is not available to you for 2018.

  • Register by June 30, 2019 if you have 25 providers or more and are interested in this method for 2018.

Submit

Meet the deadline - MARCH 31, 2019

If you need help, we are here for you.

2018 Important Reminders

  1. It is time to update the diagnosis codes in the Practice Management System. This is a task you must do every year if you are an on-premise client. New codes are effective as of 10/1/2018.

  2. Complete your MIPS targeted review if needed. – 10/15/2018.

  3. Make sure you have an upgrade plan to be on a 2015 certified EHR technology application prior to January 1, 2019. 17.3 is acceptable, 18.2 is available and has some cool features as well.

2019 MIPS Payment Adjustments

Hopefully, you have already reviewed and potentially downloaded your Performance Feedback Report from the Quality Payment Program website. I would like to encourage you to log in again and review updates made to scores and most importantly payment adjustments on September 13, 2018. 

Many practices have submitted Targeted Reviews to CMS and because of identified issues and resulting corrections, the Performance Feedback Reports of all practices impacted have been updated, not just those who submitted the Targeted Review.

If you have not filed a Targeted Review, please log in to the Quality Payment Program website and review your Performance Feedback Report again.

  1. Validate that the facility associated with the TIN is correct. If not, you can correct this in the Targeted Review submission.

  2. If you reported as an individual, validate that the TIN/NPI combination is correct. If not, you can update this in the PECOS system, but I would still encourage you to submit a Targeted Review so that any adjustments can be made on the QPP side as well.

  3. Validate that the score in each section matches the score you originally submitted for each section, and that your overall score is correct. If there is any issue, submit a Targeted Review.

  4. If you find any discrepancies or numbers that look concerning, submit a Targeted Review.

Due to the number of identified issues, CMS is extending the timeframe for submission until October 15, 2018 – 8:00 pm EST. The sooner you get your targeted review request submitted, the more likely it will be completed and thus your payment adjustment calculated and applied accurately for the 2019 payment year.

If you need additional assistance with the Targeted Review process, you can click here for the user guide. We are also happy to assist as needed.