Everything You Need To Know About MIPS Quality in 2019 Part 2: Scoring

In our last blog we gave an overview of the MIPS Quality Performance Category and discussed its reporting requirements. This week, we'll look more in-depth at how this category will be scored for the 2019 performance year.

RELATED: Everything You Need To Know About MIPS Quality in 2019 Part 1: Reporting Requirements

Measure Achievement Points

Each Quality measure submitted for the 2019 performance period will receive between 1 and 10 points as measure achievement points. Quality measures fall into one of three categories for scoring:

*These policies do not apply to CMS Web Interface and administrative claims measures.

Scoring Exception: Topped Out Measures

The only exception that exists for these scoring standards is the consideration of measures that are considered "topped out." A topped out measure is a measure with performance is so high and unvarying that there are no meaningful distinctions or improvement to performance. The overall plan is to identify and phase out these measures over a three year period. Measures that have been topped out for 2+ years will be capped at 7 possible points per measure.

Measure Benchmarks and Decile Scoring

Each submitted measure will be assessed against its national benchmark to determine how many achievement points the measure earns. Benchmarks can be established in two ways: (1) historical benchmarks based on data from two years prior to the performance period or (2) from data submitted during that performance period. Only historical benchmarks are available prior to the end of the performance period.

How do the benchmarks get converted into measure achievement points?

Each submitted quality measure is assessed against its collection type-specific benchmark to see how many points are earned based on performance. Each quality measure is converted into a 10-point decile scoring system, except for:

• Topped-out measures capped at 7 points
• Measures that don’t meet data completeness criteria
• Measures with no benchmark
• Measures with less than the minimum volume of cases submitted (>20 cases for most measures; >200 cases for readmissions)
• Measures with No Benchmark

Quality measures that can’t be reliably scored against a benchmark due to falling below the case minimum, or quality measures without a benchmark, will receive 3 points unless a benchmark can be established with performance period data. Measures that do not reach the data completeness threshold per their collection type will be capped at 1 point (3 points for small practices).

Eligibility Measure Applicability (EMA)

If you submit less than six measures or no outcome/high priority measure using the collection type of either Medicare Part B claims (small practices only) or MIPS CQMs, CMS will use the Eligibility Measure Applicability (EMA) process to determine if you could have submitted additional clinically related measures within the same collection type. If CMS determines you have submitted all applicable measures per that collection type, the number of maximum points available in the Quality performance category will be reduced. This will adjust your Quality performance score positively so that you are not penalized for not having enough applicable measures.

The EMA process does not apply to eCQMs, QCDR measures, and CMS Web Interface. Participants who submit using these collection types in conjunction with Medicare Part B claims and/or MIPS CQMs will also not be eligible for EMA.

Category Bonus Points

End-to-End Reporting Bonus

MIPS eligible clinicians and groups will receive 1 bonus point per measure for reporting quality data directly from 2015 Edition CEHRT without any manual manipulation. This bonus is available to measures reported through the Direct, Log-in and Upload, and CMS Web Interface submission types. End-to-end bonus points will be added to your Quality performance category achievement points (those earned based on performance) and are capped at 10% of your Quality performance category denominator.

New for 2019: If submitting eCQMs, 2015 Edition CEHRT is required to collect the eCQM data. The 2015 Edition EHR used to collect the eCQM data will need to be certified by the last day of the Quality performance period (December 31, 2019). Therefore, in order for practices to earn the end-to-end bonus for reporting eCQMs for the 2019 performance period, they will need to be reporting using the latest version of the eCQM and will need to use CEHRT that has been certified to the 2015 Edition.

Bonus for Additional Outcome or High-Priority Measure(s)

There are bonus points for submitting additional measures including 1 bonus point for each additional high priority measure, and 2 bonus points for each additional outcome and patient experience measure. Bonus points will be added to Quality performance category achievement points and are capped at 10% of the Quality performance category denominator. Beginning in 2019, high priority measure bonus points will not be applied to measures submitted via the CMS Web Interface. Please note, that this is separate from the 10% cap on the end-to-end reporting bonus. Bonus points are added to the Quality performance category achievement points and can be earned in addition to the bonus points available for end-to end electronic reporting.

Small Practice Bonus

The small practice bonus will now be added to the Quality performance category, rather than in the MIPS final score calculation. Beginning in 2019, six (6) bonus points will be added to the numerator of the Quality performance category for MIPS eligible clinicians in small practices who submit data on at least 1 quality measure.

Improvement Scoring

For the 2019 performance period, CMS is continuing to provide an opportunity to earn improvement points. Here, participants can earn up to 10 percentage points based on the rate of their improvement in the Quality performance category from the year before. Bonus points will be incorporated into the overall Quality performance category score.

Eligibility for Improvement Scoring

Participants will be evaluated for improvement scoring in 2019 when you:

• Participate fully in the Quality performance category for the current performance period (submit 6 measures/specialty measure set with at least 1 outcome/high priority measure OR submit as many measures as were available and applicable; all measures must meet data completeness requirements); AND
• Have a Quality performance category achievement percent score based on reported measures for the previous performance period (Year 2, 2018); AND
• Submit data under the same identifier for the 2 performance periods, or if we can compare the data submitted for the 2 performance periods. Please review Appendix E for details on how we’ll compare data across identifiers.

Improvement Score Calculation

Improvement scoring is calculated by comparing the Quality performance category achievement percent score from the previous period to the Quality performance category achievement percent score in the current period. Measure bonus points are not included in improvement scoring.

Calculating the Quality Performance Category Score

The weight of the Quality performance category is at least 45% of the MIPS final score. You can determine your Quality performance category score by using the following equation:

Facility-Based Measurement Scoring

Beginning with the 2019 performance period, CMS will identify clinicians and groups eligible for facility-based scoring. These clinicians and groups may have the option to use facility-based measurement scores for their Quality and Cost performance category scores.

Facility-based measurement scoring will be used for a clinician or group's Quality and Cost performance category scores when:

• They are identified as facility-based; and
• They are attributed to a facility with a Hospital Value-Based Purchasing (VBP) Program score for the 2019 performance period; and
• The Hospital VBP score results in a higher score than MIPS Quality measure data they submit and MIPS Cost measure data.

If you would like to learn more, dig even deeper by enrolling in the Value-Based Care Institute (VBCI) course on Quality.