The quick answer is NO!
There has been quite a bit of discussion, and some press, about the reporting period for MIPS for 2020. I have seen a few articles saying that no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in the Center for Medicare & Medicaid Services (CMS’s) calculations for the Medicare quality reporting and value-based purchasing programs. However, if you read the Quality Payment Program – COVID-19 Response, Updated 6/24/2020, there is no mention of an all-inclusive change to the reporting period.Perhaps the confusion comes from a press release that CMS issued in March that indicated for all hospital and post-acute care (PAC) quality programs, the 2020 reporting for the first half of the year was waived. This was not true for the QPP program.
Healthmonix meets with the CMS QPP team in monthly registry calls, where we discuss specifics about the program and any issues or concerns. In our last meeting, CMS reiterated that the reporting period is the entire 2020 calendar year. There is no pass on the first half of the year.
It may be difficult to capture the data for the entire year with the impact COVID-19 has had in everyone’s practices. In addition, changes in workflows that have occurred due to safety practices, telehealth and staff changes impact everyone’s success in respect to performing appropriate quality actions and capturing the related data. This makes it even more critical to ensure your quality reporting approach is defined sooner rather than later.
Whether your practice was closed for any significant amount of time or not, you will want to review and utilize data starting from the beginning of the year for MIPS reporting. In fact, if you utilize that data, it may be stronger than data later in the year. There is plenty time left to analyze and increase performance before the end of the year. Don’t consider this a ‘throw-away’ year. You’ll regret that in 2022. Despite almost 50% of people who responded to Healthmonix’s recent Surviving COVID-19 survey saying they hoped CMS would end the MIPS program as a result of the coronavirus, clearly the program is here to stay.
The bar had been raised for quality reporting in 2020 prior to the pandemic per the 2020 QPP rule. The thresholds are higher, many quality measures have been removed, and many measures are topped-out, meaning a lower score even if performance is maintained at a prior level. Less providers will hit the exceptional performance thresholds due to these factors, so there is potentially more incentive money for those that perform well.
CMS will be putting out the proposed 2021 rule any day now and we’ll see if there is any addition PROPOSED guidance. If so, we will let you know. In the meantime, our Healthmonix team is here to help. With our veteran support and integration teams, we are in position to set you up for success. Utilize MIPSpro’s real-time dashboards and drill-down capabilities to attack the gaps in care and maximize your performance. Get started today!