MIPS 2020 Reporting: Documentation Details, Timelines and Payment Adjustments

Managing your Merit-based Incentive Payment System (MIPS) is typically top of mind this time of year.  And while MIPS can be challenging, we wanted to take a moment to review the category expectations, timelines and deadlines.

Performance is evaluated across four categories, each with different weights: CMS finalized the following performance thresholds and category weights for the 2020 performance period (which corresponds to the 2022 payment year):

• Quality
• Cost
• Improvement Activities
• Promoting Interoperability

One of the most important areas to examine is the scoring system.  For example, the performance threshold is 45 points. The additional performance threshold for exceptional performance is 85 points.

Performance Categories

Significant dollars are at stake.  Positive payment adjustment could be up to +9%, and the maximum negative payment adjustment is −9%. Following the performance period, if you submit 2020 data for MIPS by March 31, 2021, you will receive a positive, negative, or neutral payment adjustment in the 2022 payment year, based on your MIPS Final Score.

• The Quality performance category assesses the quality of care you deliver based on measures of performance. For the 2020 reporting period, the Quality performance category is weighted at 45% and is collected over a full year.  There are a number of updates as compared to the previous year. For example, a new update to note is the inclusion of new specialty sets, including speech-language pathology, audiology and clinical social work. 
• The Cost performance category assesses the cost of the care you provide based on your Medicare claims. Cost measures are also used to gauge the total cost of patient care during the year or a hospital stay. The Cost performance category is weighted at 15 percent. Cost measures are evaluated automatically through administrative claims data and you do not need to submit data.
• The Improvement Activities performance category assesses your participation in clinical activities that support improvement and patient engagement, care coordination, and patient safety. This category is weighted at 15 percent.
• The Promoting Interoperability performance category focuses on the electronic exchange of health information to improve patient access to their health information, exchange of information between providers and pharmacies, and systematic collection, analysis, and interpretation of healthcare data. This performance category is weighted at 25 percent. You must submit collected data for certain measures from each of the four objectives measures (unless an exclusion is claimed) for the same 90 continuous days (or more) during 2020.

Summary of Requirements

Want to make sure you meet all the requirements? Here’s a quick summary of the key items that should be on any wound care providers checklist:

• Check your eligibility. Ensure you understand how MIPS eligibility and the low volume threshold are determined for your reporting. Review the eligibility determination periods and snapshots throughout the year.
• Determine if you are reporting as an individual or as a group.
• Determine your reporting method. Reporting can be completed via Electronic Medical Record, Quality Registry, Qualified Clinical Data Registry, or Medicare Part B Claims.
• Review the changes to performance thresholds, payment adjustment, and reporting categories.
• Understand the MIPS category requirements and timeframes for each category captured.
• Align your documentation workflows, maintain your data validation and audit (DVA) folder, and review your MIPS reports early and often.
• Report your MIPS documentation by March 31, 2021.

For additional information, check out this article in Advances in Skin & Wound Care by Net Health’s VP/Chief Clinical Officer for Wound Care, Cathy  Thomas Hess, BSN, RN, CWCN here.

Note: Clinicians continue to need the 2015 Edition of the certified electronic health record technology to report data for the Promoting Interoperability performance category and to report electronic clinical quality measures for the Quality performance category. Another good source of information is found in the CMS Regulations and Guidance Legislation.

There are exceptions . . .

CMS provides an opportunity for qualifying clinicians and groups to apply for exceptions to meeting the MIPS program requirements. One type of exception is called the Extreme and Uncontrollable Circumstances Exception Application. This application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance or public health emergency, such as COVID-19, that is outside of your control.  You can sign up for this exception through December 31, 2020, 8 p.m. ET. 

Another exception is the Promoting Interoperability Performance Category Hardship Exception Application. This application allows you to request reweighting specifically for the Promoting Interoperability performance category if you met certain criteria.  You can sign up for this exception through December 31, 2020, 8 p.m. ET.   It is important to refer to the Quality Payment Program website at https://qpp.cms.gov  for all information.

We’ve been helping wound care providers navigate the complex world of MIPS since Day 1.  We are here to help. For more information, be sure to check out our infographic or contact us at 1-800-411-6281, option 3.