We know the current regulatory updates for the Quality Payment Program (QPP) program. To date, CMS has issued many changes. The 2019 MIPS reporting requirement had an extended deadline and options for hardship exemptions. The 2020 MSSP program reporting period had many changes in both of the interim final rule with comment periods (IFCs) issued by the Centers for Medicare & Medicaid Services (CMS), at the end of March and the end of April. CMS has also added a COVID-19 improvement activity to the 2020 program, that provides full credit for the Improvement Activity category for MIPS, if an individual or 50% of a group (TIN) participates in clinical trial reporting. No changes to the reporting window or other parameters of the program have been issued.
With the exponential adoption of telehealth through this period, we know that the MIPS quality measures to be reported will be affected. Organizations have two options for quality reporting when a large portion of their visits move to telehealth:
- Stick with the measures that the practice already is familiar with. In some cases, the number of patients that are eligible for reporting will significantly decrease, as patient visits that are telehealth are not eligible to be included in the measure. That’s okay, in fact, potentially desirable. Just because the number of eligible visits is reduced does not in any way lessen the scoring of the measure.
EXAMPLE 1: A practice has 100 patients, and has in-person visits (with appropriate denominator codes) with forty of them, with the rest of the visits being virtual. In reporting Quality ID #128, Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, note that it very specifically says that visits with telehealth modifiers GQ, GT, 95, POS 02 are excluded from this measure. Therefore, the practice would report this measure for 40 patients, and the measure would be met, not met, or excluded for just those patients. So if the measure was met for all the in-person visits, the practice would have a performance rate of 40/40 or 100%. The virtual visits do not factor into that equation.
EXAMPLE 2: A practice has 100 patients, and has in-person visits (with appropriate denominator codes) with forty of them, the rest are all virtual. In reporting Quality ID Measure #111: Pneumococcal Vaccination Status for Older Adults, this measure DOES NOT exclude visits with telehealth modifiers. Therefore, the practice would need to report this measure for all 100 patients with the appropriate denominator even though the visits were virtual. So, if the measure was met for all the in-person visits, but NOT for the telehealth visits, the practice would have a performance rate of 40/100 or 40%. The virtual visits in this case DO factor into that equation.
- Choose measures based on their applicability to telehealth visits. If a practice wants to decrease their reporting population, they can select measures that DO NOT apply to telehealth. If they want to capture all patient visits in their reporting, they may choose different measures.
Based on our analysis of data in the past, we see that quality measure performance often is lower for telehealth visits. While this may not be true in every practice, we are encouraging practices to consider their quality measures and procedures to ensure a continuing level of performance. New processes may be needed to ensure quality is maintained and documented appropriately. After changes are instituted in practices, a reassessment of procedures to determine the impact of changes should be considered. Preventive measures should not be skipped, but perhaps delayed or altered, to ensure a balance between social distancing and everyone’s health.
In addition, it seems likely that the population that will have visits this year may consist of patients that have more severe conditions or comorbidities than average. Many patients that are healthier or considering elective procedures are holding off on medical care until after the pandemic subsides. Therefore, we may see lower performance on measures based on this factor as well.
For the MIPS 2020 performance period, more measures are being introduced into the Cost category of MIPS. While the impact of the Cost category is not increasing this year from a percentage standpoint, the number of Medicare providers impacted by this category is growing due to this factor.
There are 10 new measures:
Acute Kidney Injury Requiring New Inpatient Dialysis
Elective Primary Hip Arthroplasty
Femoral or Inguinal Hernia Repair
Hemodialysis Access Creation
*Inpatient Chronic Obstructive Pulmonary Disease Exacerbation
*Lower Gastrointestinal Hemorrhage
Lumbar Spine Fusion for Degenerative Disease, 1-3 Levels
Lumpectomy, Partial Mastectomy, Simple Mastectomy
Non-Emergent Coronary Artery Bypass Graft
Renal or Ureteral Stone Surgical Treatment
For specialists involved in these episodes of care, the Cost component may show up in their 2020 MIPS scoring. They will need to become more aware of the costs of care for their patients and work to reduce the cost in order to obtain a better MIPS score and increase incentives. With the pandemic, the cost of some of these episodes may be affected.
For those in the midst of EHR implementations or transitions, the pandemic may be causing delays or cancellation of these plans. In those cases, we’ll need to review the Promoting Interoperability category of MIPS and determine the impact. Perhaps a hardship exemption needs to be requested. Perhaps additional work is needed in developing processes around the technology implementation.
The implications of the pandemic are widespread. As we learn more, we’ll share, discuss and work to provide efficient solutions. To learn more about where MIPS reporting and CMS are headed, as well as the increasing importance of the Cost component of MIPS, register for our upcoming webinars.