We are quickly coming close to the end of 2017, the first year of the Quality Payment system transition for Medicare. You have most likely done a great deal of work to get you to this point and if you haven’t, it’s never too early to start planning for next year! Often times, everyone is very focused on the day to day tasks necessary to perform well with the program that they almost forget the final step. The MIPS submission method you plan to use to send all of this data and get your final performance score.
Reporting the data to the Center for Medicare and Medicaid Services (CMS) is a required step to avoid penalty and to get your performance score. It is also an important step that should be given some thought prior to selecting your submission method.
MIPS Submission Method & Performance Categories
Providers will have the ability to pick a different submission method for each performance category (Quality, ACI and Improvement Activities). However, only one submission may be used for each category. Which basically means you can’t send some Quality data via two different submission methods. You may use one method for Quality and another for Advancing Care Information and even another for Improvement Activities.
There are a number of factors to consider when selecting the MIPS data submission method for your practice:
- Measure Availability
- Workflow Impact to Your Practice to Capture Data
- Ease of Submitting Data to Submission Vendor
- Potential Bonus Points
There is also some strategy needed to select the method that will get you the performance highest score. You will want to review all of your options to maximize your total points and gain the most incentive for your practice. There are pros and cons to each MIPS data submission method.
MIPS Submission Method & Benchmarks
It is important to note that the benchmarks for each quality measure will vary depending on the submission measure you choose. These benchmarks are very important since Quality represents at least 60% of your MIPS score for 2017. The Quality component could actually be weighted higher if you are excluding from other components of the program such as Advancing Care Information. If your goal is to get the highest score possible, you will need to review the benchmarks closely to get the most out of your performance.
I have mentioned the impact of the submission method and your score several times. The table below represents the variation of the benchmarks and how your score will be impacted for a sample measure:
Benchmarks for Measure 110 -Preventive Care and Screening: Influenza Immunization
|11.57 - 21.39||21.40 - 31.39||31.40 - 41.31||41.32 - 51.13||51.14 - 62.04||62.05 - 74.27||74.28 - 91.83||>= 91.84|
|EHR||11.22 - 18.57||18.58 - 24.99||25.00 - 31.84||31.85 - 38.92||38.93 - 47.86||47.87 - 59.99||60.00 - 79.01||>= 79.02|
|Claims||22.64 - 31.75||31.76 - 43.13||43.14 - 54.68||54.69 - 66.38||66.39 - 77.47||77.48 - 92.03||92.04 - 99.99||100|
Let’s review the MIPS submission methods in some more detail!
EHR Vendor Submission
Many times, providers don’t fully realize all of the options available to them. For instance, many providers are under the impression that they must use their EHR vendor’s reporting tools to submit data for the quality payment system. While, it may make the submission process simpler, it may not necessarily be the best option for your practice.
Here are pros and cons to using your EHR vendor for a MIPS submission method.
- Measures available in the EHR may give you higher benchmarks
- You have no additional data extraction work necessary to submit the data
- The practice could just “click the vendor buttons” to score well in the selected measures
- The practice relies heavily on the EHR vendor for measure selection
- Often limited and may not meet your practice requirements
- Your clinical workflow will most likely have to be altered to meet vendor requirements that may not make sense for your practice
- Many vendors are struggling to meet regulations for software development which leads to lots of fixes and upgrades
Qualified Clinical Data Registry & Certified Registry
For those practices that decide having this much dependency on their vendor is not right for them, a certified registry may be the best alternative option. Using a Certified Registry to submit your data may give you just the flexibility you are looking for. Many registries are also a Qualified Clinical Data Registry which will allow for those higher benchmarks.
Here are a few pros and cons to using Certified Registries for a MIPS submission method.
- Generally, you will have access to report more measures than via direct EHR submission
- If your registry is also a Qualified Clinical Data Registry, your Quality score will get the benefit of the higher benchmarks
- The practice can adjust their clinical workflows as desired as long as they can get the data to the registry
- You won’t be “stuck” with the vendor specific workflow
- There is a great deal of competition so you may be able to get a better price
- There will most likely be some work to do within your system to get the data to the registry
- Unless you select a registry that has some direct links to the EHR systems
- You may need to complete spreadsheets or find other alternatives to get data out of your system
- Not all registries give you the ability to submit Quality, ACI & Improvement Activities so you would need to use more than one submission method for the program as a whole
If you do not want to use your EHR or a Certified Registry, Claims submission continues to be an option under the MACRA program. Practices could decide to report their selected measures via claims as an alternative to gathering all of the clinical data for submission to a registry.
Here are a few pros and cons to using Claims for a MIPS submission method.
- No additional cost for submitting data
- No extra data extraction work necessary to submit data to CMS
- Flexible workflow options
- Only available for Individual Reporting
- Limited measures selection
- Higher benchmark requirements could lead to a lower performance score
- There is often a disconnect between the clinical workflow and billing which could cause poor performance
- Without custom programming to the EHR, providers or billing staff would need to enter the correct codes into the billing system for processing
CMS Web Interface
If you are a group of over 25 providers, you may have selected to use the CMS Web Interface for reporting. This option is only available for group reporting and practices had to registry for it before June 30, 2017. This submission method does require you to report on 14 measures for the entire calendar year.
Which MIPS Submission Method Do You Choose?
My answer to this question is there is no one answer for all group. The process simply isn’t that black and white. There are many shades of gray! The best choice really depends on your practice and what your goals are. For some providers the goal is to score as high as possible and they are willing to do extra work to get that score. Others may want to score well but do not want to change their workflow significantly. The choice ultimately takes a good deal of review and discussion. We are quickly closing in on the end of 2017 so if you haven’t begun to plan for this, now is the time.