MIPS submission mechanisms for all performance categories

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The Medicare Merit-Based Incentive Payment System (MIPS) will begin on January 1, 2017, and providers across the country are considering which submission mechanism makes most sense for them. Here is a handy reference for you to see which submission mechanisms are available for each performance category, as well as additional details about data submission for the Quality performance category.

Here are some questions to consider as you think about your 2017 submission strategy, which could impact your choice of submission mechanism:

  • Will you be focused on reporting the minimum necessary data to avoid a penalty, or are you setting up your processes in 2017 for maximum performance next year and beyond?
  • What is your current setup for participating in PQRS or other programs that require performance reporting? Can you leverage existing processes?
  • Are you able to select a submission mechanism that enables you to submit data across all relevant categories in order to simplify the process?
  • Which submission mechanisms support reporting for your preferred Quality measures?

Submission mechanisms for each MIPS performance category

The following table outlines which submission mechanisms can be used for each MIPS reporting categories for those reporting as individuals and those reporting as groups.

Performance category Individual reporting data submission mechanisms Group reporting data submission mechanisms
 Quality
  • Claims
  • QCDR
  • Qualified registry
  • EHR
  • QCDR
  • Qualified registry
  • EHR
  • CMS Web Interface (groups of 25 or more)
  • CMS-approved survey vendor for CAHPS for MIPS (must be reported in conjunction with another data submission mechanism)
  • Administrative claims (For the all-cause hospital readmission measure—no submission required)
Improvement Activities
  • Attestation
  • QCDR
  • Qualified registry
  • EHR
  • Attestation
  • QCDR
  • Qualified registry
  • EHR
  • CMS Web Interface (groups of 25 or more)
 Advancing Care Information
  • Attestation
  • QCDR
  • Qualified registry
  • EHR
  • Attestation
  • QCDR
  • Qualified registry
  • EHR
  • CMS Web Interface (groups of 25 or more)
 Cost (does not contribute to the Composite Performance Score in 2017)
  • Administrative claims (no submission required)
  • Administrative claims (no submission required)

Submission details for the Quality performance category

The following table outlines requirements specific to the Quality performance category for each eligible submission mechanism.

Submission mechanism Individual or group reporting Performance period Data completeness requirement
 Part B Claims Individual MIPS eligible clinicians A minimum of one continuous 90-day period during CY2017 50% of MIPS eligible clinician’s Medicare Part B patients for the performance period
QCDR
Qualified Registry EHR
Individual MIPS eligible clinicians or groups A minimum of one continuous 90-day period during CY2017 50% of MIPS eligible clinician’s or groups patients across all payers for the performance period
CMS Web Interface  Groups Jan 1 – Dec 31 Sampling requirements for their Medicare Part B patients

Number of quality measures supported by each submission mechanism

The following table displays the number of quality measures that can be reported via each eligible submission mechanism. Click here to download the full list of MIPS quality measures, filterable by submission mechanism.

Submission mechanism Number of quality measures supported
Claims  74
EHR 53
Qualified Registry/QCDR 243
CMS Web Interface 15


Further reading:
Should I just do the minimum? 3 Reasons clinicians and groups are going all out in MIPS this year
MIPS Advancing Care Information: Frequently Asked Questions

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