What to Do in the Last 90 Days of MIPS 2020

The last 90 days of the year. Many might be ready to say goodbye to 2020 as a year filled with challenges, adjustments and ever-shifting expectations in our personal and professional lives. For those clinicians who are eligible for participation in the Merit-Based Incentive Payment System (MIPS), the last 90 days of the year also represents the beginning of some measurement periods and the final opportunity to improve in others.

Here are some tips for each performance category that you can leverage to ensure MIPS success within the last 90 days of the year:

Quality

Focus on measures with the highest scoring opportunity. Hopefully, you have tracked performance throughout the year in Quality measures that are relevant in your practice. Assess where your performance stands within those measures and look at the measure benchmarks.

• Are there any measures that can increase your score by improving performance slightly?
• Are there topped out measures in which you have low performance but can raise your score above your high-performing  MIPS measures?
• Are there measures where you did not meet performance with a patient? Can you schedule a visit with that patient to close a performance gap before the end of the year?

Improvement Activities

Make sure you have your Improvement Activities picked out and have a plan for implementing or continuing to perform the activity for at least the last 90 days of the year. If you have already performed the activity for 90 consecutive days, great! You will be ready to attest to completing the activity when it becomes submission time.

• Remember, at least 50% of eligible clinicians within a group need to participate in the activity, up from only one eligible clinician in previous years with group reporting.
• Consider reporting on the new COVID-19 Improvement Activity: COVID-19 Clinical Data Reporting with or without Clinical Trial.
• You can attest to Improvement Activities (IA) you performed during the 2019 performance year unless otherwise indicated in the activity description. If doing so, make sure your IA are still available in 2020 as some have been modified or removed.

Promoting Interoperability

Review your EHR and confirm that it’s 2015 CEHRT. Ensure you have the capability to perform each of the Promoting Interoperability measures during the 90-day performance period.

• Check that you can or have already received and sent electronic referrals or transitions of care.
• Identify your two registries for meeting the Public Health and Clinical Data Exchange measures and begin active engagement before the end of the performance period.
• Perform or review your Security Risk Analysis. You do not need to perform the analysis within your 90-day reporting period, but it does need to be performed annually.

Cost

Become familiar with the category measures and how they are scored. While Cost measure data is collected directly by Medicare and does not require additional data submission, the performance category weighting is increasing in future MIPS years until it reaches an equal weighting with Quality.

• Determine if you may have eligible cases for any of the previously existing measures such as MSPB, TPCC or the episode-based measures added in 2019, or any of the additional episode-based measures added in 2020.
• Check your 2019 Performance Feedback reports to see how you scored in Cost last year.
• Consider whether tracking Cost performance with a tool like REVlytix would provide additional value to your practice.

Whether you are a MIPS novice taking over reporting responsibility for your practice for the first time or a seasoned veteran of value-based care, make sure you make the last 90 days count. We hope these tips will help. For more insights on optimizing your 2020 MIPS performance, check out our Advanced Strategies for MIPS 2020 Success webinar or contact us today to discuss your specific needs.