Need to Know: What are my options for submitting data for each MIPS performance category?

As you know by now, 2017 is a Transition Year for MIPS. This means that with minimal participation, you can avoid the negative payment adjustment, which will be applied in 2019 based on 2017 performance data.

But we also know that there are significant benefits to achieving high performance in 2017. What reporting flexibility do you have to maximize your performance across the three categories, Quality, Advancing Care Information, and Improvement Activities?

1. Submission Mechanisms

Performance categories can be reported via different submission mechanisms, though many eligible clinicians and groups are glad to consolidate the work. Below are your options for submission mechanisms in each category:

Performance Category Submission Mechanisms
Quality Claims
QCDR
Qualified Registry
EHR
Advancing Care Information Attestation
QCDR
Qualified Registry
EHR
Improvement Activities Attestation
QCDR
Qualified Registry
EHR

2. 90-day period

In 2017, you are able to reach the maximum performance level by submitting 90 days of data in each performance category. You are allowed to submit data for different 90-day periods across the three categories. This means that you could submit data for the Quality category for June-August, and submit data for ACI from September-November.

3. Group vs. Individual reporting

Although you can report on different 90-day periods for different performance categories, all clinicians within a TIN that is reporting as a group must use the same performance period for each performance category. This is consistent with how CMS evaluates groups overall, treating the group as a super-clinician, where all the group’s data is evaluated in the same way one clinician’s data would be evaluated.

Along those lines, all eligible clinicians within a group that is reporting as a group must report the same measures in all performance categories. All data within that group will be looked at as if the group is one super-clinician, which means that if a patient has an eligible encounter that puts them in the denominator of a measure, all clinicians are together responsible for meeting the numerator criteria in selected measures, regardless of which specialist the patient sees. This has been a point of concern for many multispecialty groups, who are worried that specialists are responsible for providing care that is irrelevant to their specialty. The reasoning behind this requirement is that the group has collectively taken responsibility for the patient’s care. As a result, some multispecialty groups are electing to report individually for all clinicians.

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Further reading:
Quick-Look Comparison: MIPS 2017 vs. 2018 requirements
Need to Know: Highlights from the 2018 QPP Proposed Rule and What It Means for You

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