Are you wondering how MIPS reporting in 2020 will be affected by the COVID-19 pandemic?  Are you holding off reporting because you are uncertain as to the requirements for 2020?  Has the responsibility of MIPS reporting shifted with the impact of the pandemic on your organization?

CMS has issued a variety of updates over the last two months regarding the Quality Payment Program (QPP).  There have been updates to the program, but so far there is no guidance that anyone will receive a ‘pass’ for 2020.  Quite the contrary.  Healthmonix attended a two-day kick-off for 2020 MIPS registries in April where the Centers for Medicare and Medicaid Services (CMS) reiterated and clarified requirements for 2020.  Just last week, CMS issued guidance clarifying 2020 reporting requirements per the final rule issued at the end of last year.  There is a new improvement activity for 2020 related to COVID-19.  As far as we have been told, the program is still intact for 2020. 

As such, we are encouraging those that have the time and energy currently to think about a strategy for 2020.  As we move forward through the year, we all are going to face periods where our practices are shifting, where there are periods of intense work, and hopefully, a few breathers where we can plan.   

Here are some overarching considerations as you think about reporting for 2020:

• CMS has raised the bar for quality tracking in 2020. The requirement for quality reporting is now a 70% sample of group or individual patients / visits.  Many clinically low-bar, standard of care, and process measures have been removed.  High-priority outcome measures are becoming a focus. 
• Much care has shifted to telehealth. This will impact which quality measures are applicable to your practice, as some measures are relevant to telehealth and others are not.  You can view a list of measures that are relevant to telehealth here.
• In the Improvement Activity component, for groups, at least fifty percent of the group must participate in the activity (changed from one participant). Documentation must be kept for audits.
• There is a new COVID-19 Clinical Trial improvement activity for those that are treating COVID-19 patients. In order to receive credit for the new MIPS COVID-19 Clinical Trials improvement activity, clinicians must attest that they participate in a COVID-19 clinical trial utilizing a drug or biological product to treat a patient with a COVID-19 infection and report their findings through a clinical data repository or clinical data registry for the duration of their study.  

There’s no ‘easy button’ in 2020 without proper planning.  The threshold for incentives has been raised to 45 points for a total MIPS score.  In order to achieve this threshold, organizations can no longer wait until late in the year to start thinking about how to participate.  If you have a tracking mechanism in place for quality measures and promoting interoperability, either through your EHR or an integrated registry, this threshold is much easier to achieve.  We’ve been working with many EHRs to integrate our  MIPSpro dashboards to seamlessly track so quality becomes embedded in the practices and is not an afterthought or an extra burden.

While we have received no guidance from CMS regarding changes to reporting requirements for 2020, it is our impression that CMS could still make changes to lessen the burden for 2020.  One possibility is that they exclude the first half of the year as they have with other quality programs.  Another is that they could allow a flexible reporting period.  In either case, continuing prior practices will provide the ability to optimize scores.

To learn more about the changes that CMS has made to MIPS 2020, register for our upcoming webinar: MIPS 2020 Rules and Regulatory Changes.

As always, we strive to keep you well-informed.  If you have thoughts regarding the program, we’re happy to hear and share.  Stay safe.  Stay healthy.  And thank you for all you do!