Help! I can’t find six relevant MIPS measures for my specialty

If you represent a specialty and have had trouble finding relevant quality measures in past year for PQRS or this year for MIPS, there is some good news for you this year. The first piece of good news is that unlike PQRS, MIPS offers partial credit for partial reporting, so even if you report just one quality measure you will earn points that will enable you to avoid the negative payment adjustment, and might earn you a small incentive.

Additionally, under MIPS you have the option of submitting all quality measures within a specialty set. In some cases, this may comprise fewer than six measures. If you submit fewer than six measures, or if you do not include the required outcome or high priority measure in your measure set, CMS will use the Eligible Measure Applicability (EMA) process to determine if there are any other measures you could have submitted.

  • If it is determined that you could have submitted more measures, you will still get credit for the ones you submitted.
  • If it is determined that you could not have submitted more measures, your total possible points in the category will be lower, so that you only have to report, for example, 4 measures to earn a total possible 40 points in the category (see additional details about this example below).

Here are some commonly asked questions about EMA to help you understand this sometime opaque process.

How does EMA work?

If you submit fewer than six quality measures, or do not include an outcome or high priority measure, CMS will use a two-step process to determine whether there were other measures you could have submitted. The process includes:

  1. A Clinical Relation Test to determine if there are more clinically related quality measures based on the one to five quality measures you submitted. Alternatively, if you have submitted six measures but none are an outcome or high priority measure, then a Clinical Relation and Outcome/High Priority Test will determine if there is a clinically related to an outcome or high priority.
  2. A Minimum Threshold Test, which looks at the Medicare claims you submitted to see if there are at least 20 denominator eligible instances for any extra measures found in Step 1.

Example

Let’s say you submit four quality measures. Here are two scenarios:

  1. It is found through EMA that you could have submitted six or more measures. Your Quality category score would be evaluated out of 60 points, and you can still earn up to 40 points for the submitted measures, meaning that your highest possible Quality score would be 40/60.
  2. Your measures set goes through the EMA process, and it is found that you could not have submitted additional measures. Your Quality category denominator would be reduced from 60 points to 40 points, so that if you earned the full 10 points on each of the four measures, then you would earn 100% in the Quality category.

Will EMA automatically be applied no matter how I submit data to CMS?

EMA will only be applied to submissions made via Registry or Claims. EHR and QCDR submissions will not be evaluated using the EMA process.

I’m frustrated because I can’t know in advance whether my measure set will pass the EMA process.

Have no fear! You can get a good sense of whether CMS will find clinically related measures by looking at this resource. It shows you which measures CMS has determined are clinically related, so you can locate the measures from your measure set on this list and see if there are any related measures that you are not reporting.

 

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Further reading:
A new era for measure development: Clinical Quality Language is here!
Radiology & MIPS Reporting: Everything You Need to Know

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