Quality is the revised version of PQRS within the Merit-based Incentive Payment System (MIPS).  Similar to PQRS, Quality encourages individual eligible clinicians (ECs) and groups to report information on the quality of care to Medicare. The Quality performance category gives participating ECs and groups the opportunity to assess the quality of care they provide to their patients, helping to ensure that patients get the right care at the right time.

MIPS does away with the traditional penalty system associated with PQRS.  Instead, an EC or group’s performance contributes to their overall MIPS Final Score which then, through comparison to the performance threshold, determines how their Part B fee schedule is adjusted two years later.

The Quality category in 2019 asks that clinicians report on 6 measures at least 60% of the time that they apply.  Each of those 6 measures reported in 2018 counts anywhere from 1 to 10 points.  A 3 point minimum score will be assigned to solo clinicians and groups of 15 or fewer for any measure that:

• does not satisfy the 60% reporting frequency requirement
• lacks 20 cases in the denominator

If each of the above are false, the actual performance on the measure will be considered by comparing the clinician’s score to a benchmark comprised all all-clinician performance two years earlier.

Ultimately, a clinician or small group’s Quality score is based the sum of points for the 6 best scoring measures reported.

There are also opportunities to earn bonus points by submitting additional outcome (2 points each) or high priority measures (1 point each) and by submitting data via certified EHR technology (CEHRT) (1 point each).  Importantly, to earn bonus points for additional outcome or high-priority measures, the measure needs to be reported successfully (i.e. ≥60% of applicable cases and have at least 20 cases in the denominator).  Planning to include additional high priority measures and/or via CEHRT, then, is a way to plan for higher scoring.  A full list of all available measures for 2019 will be available on the Quality Payment Program website.

Finally on the scoring front, 2018 offers the opportunity for up to 10 bonus points for year over year improvement.  To qualify, at least one measure needed to be reported in 2018 as the bonus aims to reward improvements in performance and not participation.

There are a number of ways that an EC or group can report data for the Quality category.  These “collection types” differ slightly based on how a clinician elects to report (individual vs. group).

Medicare Part B Claims

• available for individuals, groups, and virtual groups that are small practices

At the conclusion of an encounter, codes can be added to a CMS-1500 form to let Medicare know what quality actions were taken during a visit.  RevolutionEHR facilitates participation in claims-based reporting through the Quality Alert on the coding screen within an encounter:

The Quality Alert provides a number of, but not all, possible quality data codes for the patient based on conditions evaluated during that visit (as determined by the diagnoses appearing in Today’s Diagnoses).  As an example, a patient with a primary open angle glaucoma diagnosis appearing in Today’s Diagnoses would see the two glaucoma-related measures available for claims-based reporting appear in the Alert:

The provider can then check the appropriate measures, click “Add Selected” and the quality codes would appear in the encounter ready to be applied to the claim.  The Quality Alert will provide codes pertaining to 9 quality measures for 2019:

• POAG: Optic Nerve Evaluation
• POAG: Reduction of IOP ≥15% OR Documentation of a Plan of Care
• AMD: Dilated Macular Evaluation
• Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care
• Diabetes: Eye Exam
• Documentation of Current Medications in the Medical Record
• Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention
• Preventative Care and Screening: Screening for High Blood Pressure and Follow Up Documented
• Pain Assessment and Follow Up

Removed by CMS for 2019:  AMD: Counseling on Antioxidant Supplement

* measure in blue is an “outcome” measure (2 bonus points if reported successfully).  Measures in green are non-outcome “high priority” measures (1 bonus point if reported successfully).

** the 5 eye-specific measures will appear in the alert as pertinent to the case.  The 4 diagnosis-independent measures will appear for each encounter without regard to diagnoses.

Alternate measures that a provider might choose to report through the course of the year should be added to the Common Services list for easy addition to a claim as pertinent.  Remember that the goal is to report on 6 measures more than 60% of the time that they apply throughout the year.  Thus, providers should identify which codes fit their practice and patient base, make sure they’re available to be added to claims either through the Quality Alert or the Common Services list and develop consistency in reporting them.

Resources

• 2019 Quality Payment Program Quality Measure Search Tool
• 2019 AOA Guide to Quality Measures for Claims-based Reporters
• 2019 MIPS Quality: Claims Data Submission Fact Sheet

Electronic Clinical Quality Measures (eCQMs)

• available for individuals, groups, and virtual groups

This collection type involves the submission of statistics automatically tracked by RevolutionEHR: eCQMs.  Clinicians reporting eCQMs do not need to select the measures they will report throughout the year like Medicare Part B claims-based reporters do.  Instead, the measures that RevolutionEHR automatically tracks will be the measures the clinician reports.  These measures can be found on the MIPS – Quality scorecard (Reports > Administration > Providers > MIPS – Quality).

• Diabetes: Eye Exam
• Documentation of Current Medications in the Medical Record
• Closing the Referral Loop
• Use of High-Risk Medications in the Elderly
• Cataracts: 20/40 of Better Visual Acuity within 90 Day Following Cataract Surgery (applicable to surgeon only)
• Cataracts: Complications within 30 Days Following Cataract Surgery Requiring Additional Surgical Procedures (applicable to surgeon only)
• POAG: Optic Nerve Evaluation
• Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care

Removed by CMS for 2019:   Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy

* measures in blue is are “outcome” measures (2 bonus points if reported successfully).  Measures in green are non-outcome “high priority” measures (1 bonus point if reported successfully).

Since eCQMs effectively report on near 100% of applicable patients, satisfying the ≥60% reporting frequency requirement is automatic via this method.  Additionally, each measure submitted via this end-to-end electronic process entitles the clinician to 1 bonus point.

To submit data via this method, the clinician exports a file of clinical quality measure scores from the MIPS – Quality scorecard and uploads it to Medicare within the early part of the year following the performance year.  To accomplish the file upload, access to CMS’ Quality Payment Program portal is required.  If you’ve reported this way in the past and kept your credentials active, you’ll be able to use those again this year.  However, if they have expired due to inactivity or if you have never registered for access before you’ll need to follow a process to do so.

Fortunately, CMS has created a series of documents to help you with registration (through their new system named HARP).  At the end of that process, you’ll have a user ID and a password which will allow you access to the QPP system.  Those documents can be found below and numbered in the order to be followed.

1) Before You Begin

2) Register for a HARP Account

3) Connect to an Organization

4) Security Official: Manage Access

Resources

• 2019 Clinical Quality Measure Scoring Guide
• RevolutionEHR 2018 MIPS Data Submission Guide 

Qualified Clinical Data Registry Measures

• available for individuals, groups, and virtual groups

The American Optometric Association’s registry, AOA MORE, represents a CMS-approved QCDR.  Visit aoa.org/MORE to learn more about the benefits of AOA MORE and how registries are being used in health care.

Clinicians reporting via qualified clinical data registry (QCDR) do not need to select the measures they will report throughout the year like Medicare Part B claims-based reporters do.  Instead, the measures that the QCDR tracks will be the measures reported.

MIPS Clinical Quality Measures (formerly Qualified Registry measures)

• available for individuals, groups, and virtual groups

Qualified registries are vendors who are responsible for collecting clinical quality data, calculating reporting and performance rates, and submitting quality measures data to CMS in a CMS-specified format on behalf of a provider for the respective program year. The vendor may collect data from claims, web-based tools, practice management system, and/or EHRs. The qualified registry will enter into a contract with the EC or group practice, and may require a fee for submitting data.

RevolutionEHR has no relationships with qualified registries and, in turn, cannot assist with this method of reporting.

CMS Web Interface

• Can only be used by groups and virtual groups with 25 or more clinicians and Medicare Shared Savings Program (SSP) ACOs reporting on behalf of MIPS eligible clinicians

Registration process required for this method of reporting except for ACOs ( as it is required for these entities).  Groups planning to use this method must register between April 1, 2019 and July 1, 2019.

RevolutionEHR cannot assist with this method of reporting.

CAHPS for MIPS Survey Measures

• Can only be used by groups and virtual groups

Registration process required for this method of reporting. Groups planning to use this method must register between April 1, 2019 and July 1, 2019.

CAHPS, or Consumer Assessment of Healthcare Providers and Services, is an official survey process.  All surveys officially designated as CAHPS surveys have been approved by the CAHPS Consortium, which is overseen by the Agency for Healthcare Research and Quality (AHRQ).  To learn more about CAHPS surveys click here.  CAHPS surveys follow scientific principles in survey design and development.  The surveys are designed to reliably assess the experiences of a large sample of patients.  They use standardized questions and data collection protocols to ensure that information can be compared across healthcare settings.

If a provider or group chooses to include a CAHPS survey within their MIPS activities, the survey will be performed between November and February and count as one measure within the Quality category.  This would leave both small and large practices responsible for submitting five more measures via one of the other reporting mechanisms.  As a measurement of patient experience, it is classified as “high priority” and would entitle the group to 2 bonus points if reported in addition to an outcome or other patient experience measure.

CAHPS for MIPS is not required for groups > 100 like it was within PQRS.  Importantly, CAHPS studies need to be administered by a CMS-approved CAHPS survey vendor.  It remains at the discretion of each group as to whether a CAHPS study and the associated costs make sense for their MIPS participation.

RevolutionEHR is not a CMS-approved CAHPS survey vendor and, in turn, cannot assist with this method of reporting.

 

Quality Performance Category Resources

• 2019 MIPS-Quality discussion (Rev360)
• 2019 MIPS Quality Performance Category Fact Sheet
• 2019 Quality Measure Search Tool

Overwhelmed by MIPS?  RevAspire is a technology enabled service that supports, equips and assists you through the entire process of CMS quality reporting while freeing you to spend more time with your patients.  Learn more about the benefits of RevAspire partnership here.