Guest Post with

Written by Amanda Lord Darbani, Patient360 COO and MIPS Subject Matter Expert

If you didn’t have the chance to read the Patient360 assessment of the Proposed Rule back in August, this is a handy place to review those tables and basic updates to expect in the 2020 Quality Payment Program.

In short, if you don’t feel like toggling to the previous blog, it is pretty much what we expected and very manageable. There are a few minor changes in terms of allocation of scoring percentage changes in the various categories, but not much else has changed for 2020 reporting.  This is a quick bullet list from the CMS fact sheet:

• The performance threshold is 45 points (i.e., this is the minimum score to avoid penalty) 

• The exceptional performance threshold is 85 points 

• Quality performance is worth 45 points (i.e., no change from 2019) 

• Cost performance is worth 15 points (i.e., no change from 2019) 

• Promoting Interoperability is worth 25 points (i.e., no change from 2019) 

• Improvement Activities is worth 15 points (i.e., no change from 2019)

One minor change that continues to arise is the minimum threshold for data completeness.  As part of the 2020 Final rule, clinicians must submit greater than 70% of their patient encounters for each measure instead of the current 60%.  This was an anticipated change and likely to continue to increase in order to mitigate the ever pervasive “cherry picking.”  Essentially, report as much data as able for each quality measure and don’t pick only the “best” data. CMS is trying to avoid the latter which skews and inflates a “true” score.  Remember, the spirit of the program is to try to improve quality of ALL care vs. only demonstrating elevated performance on a subset of patients.

Also, note that the timing of the Qualified Registry randomized audits has shifted.  Patient360 and other registries are now conducting randomized audits during the course of the reporting year, prior to the end of the reporting season/performance period, in order to ensure all data is true, valid, and accurate. Registries are charged with eliminating erroneous data before it reaches CMS.  Detect and correct is the mantra!  These audits are an important part of the CMS validation process. This validation protects Patient360 clients and keeps Patient360 in good standing with CMS.  If interested in learning more, refer to a previous blog about the importance of the auditing process to maintain data integrity and best practices: 

MIPS Value Pathways (MVPs) program has received some attention as they were presented as part of the 2020 Final Rule. MVPs will be launched in 2021 and require providers to report on a smaller set of measures. Theoretically, by limiting the volume of measures, CMS will be able to effect change more readily. Based on Patient360 learning and conversations with CMS, these changes aren’t going to be made in a vacuum. CMS is absolutely seeking stakeholder feedback on the program.  In addition, the exact timeline for full program launch was NOT finalized; i.e., we only know some form of the MVP program will launch in 2021. Since the MVP program is not yet finalized it remains to be seen to what degree participation will be required.  CMS emphasized they understood a slower transition for this program is important.  For now, know the MVP program is happening in 2021 and the transition will not be a light-switch event. It will be gradual with much stakeholder feedback and involvement.   

New and Retired Measures:

Don’t feel like looking at the dozens of Appendices at the end of the Final Rule to learn which measures added vs. retired in 2020?  Patient360 has you covered!

RETIRED MEASURES:  42 in total.

46,51,68,91,109,131,160,165,166,179,192,223,255,271,325,328

329,330,343,345,346,347,352,353,361,362,371,372,388,403407,411,417,428,442,446,449,454,456,464,467,474

ADDED MEASURES: 4 in total.

476, 477, 478 and not numbered yet: Adult Immunization Status

No time to cross reference or simply enjoy perusing the riveting appendices in the Final Rule?  Here are page numbers:

Final Rule info on retired measures begins here:

TABLE C: Previously Finalized Quality Measures Finalized for Removal in the 2022 MIPS Payment Year and Future Years In this final rule, we are removing 42 previously finalized quality measures from the MIPS Program for the 2022 MIPS payment year and future years.

Final Rule info on newly added measures for 2020 begins on Page 2071, TABLE Group A: New Quality Measures Finalized for the 2022 MIPS Payment Year and Future Years

Final Rule info on significantly changed measures begins here: Page 2314, TABLE Group D: Previously Finalized Quality Measures with Substantive Changes Finalized for the 2022 MIPS Payment Year and Future Years