MIPS Submission Options 101

MIPS submission options

Are you still working to figure out the most advantageous way for your organization to submit your MIPS data? Are you unclear about the pros and cons of the various submission mechanisms? You’re not alone – it’s complicated. There are five different MIPS submission options, each of which allow for submission of certain performance categories and measures. With MIPS requirements ramping up in 2018, eligible clinicians and groups want to be sure that they are choosing the best option for their context.

Since this is a common topic of discussion among our provider community, we have laid out the basics of each performance category below.

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Submission mechanism name & overview How does it work? Things to consider We typically see providers choose this submission mechanism when…
Registry/ QCDR

Categories supported:

  • Quality
  • Improvement Activities
  • Advancing Care Information

Number of quality measures available: 249

Data is submitted to a qualified organization or is extracted from EHR and billing systems, and the qualified organization submits measure results to CMS on behalf of the eligible clinician or group. Different Registries and QCDRs vary significantly in terms of how much they automate the submission process. Some entities automatically pull data and provide real-time feedback dashboards, while others collect data in spreadsheets once per year.
  • They are specialists or multi-specialty groups who do not have appropriate measures in their EHR
  • They do not trust measure calculations from their EHRs
  • They want real-time transparency into measure performance (some Registries / QCDRs provide this type of analytics)

Categories supported:

  • Quality

Number of quality measures available: 74

Eligible clinicians and groups submit Quality Data Codes to CMS on claims. These codes are not used for FFS billing, but are specifically used to indicate that a patient met or did not meet a specific quality measures. You cannot retroactively add codes to past claims, so you need to be submitting Quality Data Codes for the full year to get full credit.
  • They already have quality data coding systems in place
  • They do not need to monitor performance throughout the year–it is difficult for most providers doing claims-based reporting to track where they stand.

Categories supported:

  • Quality
  • Improvement Activities
  • Advancing Care Information

Number of quality measures available: 53

EHRs generate standard files, called QRDA-3 files, which contain data for submission. These files can be uploaded through the QPP website, either by a vendor or by the eligible group or clinician. There are a limited set of quality measures that can be reported through an EHR, and many EHR systems do not support the full set of 53 measures, limiting the scope of choice for providers.
  • They have an EHR system that monitors all relevant quality measures (typically primary care)
  • They have an EHR system that provides a high quality and accurate performance dashboard
CMS Web Interface

Categories supported:

  • Quality
  • Improvement Activities
  • Advancing Care Information

Number of quality measures available: 15

After the submission year, groups receive a beneficiary list from CMS, and are required to report on a certain number of beneficiaries for each quality measure. This reporting mechanism is only available to groups of 25 eligible clinicians or more. You must elect to participate in web interface reporting in the summer of the performance year.
  • They have done it in the past and have a process in place
  • They would rather do a manual chart abstraction process on a sample of patients one time a year than monitor the full population on an ongoing basis
Attestation (through the CMS attestation portal)

Categories supported:

  • Improvement Activities
  • Advancing Care Information

Number of quality measures available: None

During the submission period (January-March following the performance year), providers can log in and attest for ACI and Improvement Activities, as well as upload QRDA-3s for EHR reporting. Aside from providing the location for uploading your file for EHR reporting, this method does not allow for quality measures reporting.
  • They are doing EHR or Registry/QCDR reporting and their vendor only supports Quality
  • They are doing claims-based reporting for Quality, and therefore they need another mechanism for ACI and Improvement Activities (claims-based reporting is only available for the Quality category.)


Why isn’t the Cost category in this list?

The new Cost performance category will be calculated off of administrative claims that you already submit as part of your normal Medicare Part B billing process. There is no additional data submission for this category.


Have questions? Email us at hello@ablehealth.com

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