All Texas physicians should recheck their 2017 Merit-Based Incentive Payment System (MIPS) or Alternative Payment Model (APM) information to ensure the correct MIPS payment adjustment (bonus or penalty) was applied for 2019 Medicare payments.
The Centers for Medicare & Medicaid Services (CMS) recently announced it identified errors in the data used to calculate final quality scores, performance feedback, and payment adjustments for the MIPS and APM tracks under the Quality Payment Program (QPP).
In July, Texas Medicine Today informed you about the release of final Medicare quality scores, and Texas Medicine ran a story in September on MIPS performance feedback.
Originally, CMS said physicians had only until Oct. 1 to ask for an appeal (which the agency calls “targeted review”) of their scores, feedback, and payment adjustments. However, because of the errors, CMS extended the deadline to Oct. 15.
So what went wrong? According to the CMS notice, the agency failed to:
- Award Improvement Activity credit to physicians who successfully participated in the Improvement Activities Burden Reduction Study;
- Apply the addition of the 30-Day All-Cause Hospital Readmission measure for the Quality category to the MIPS final score; and
- Apply certain exemptions or reweighting of categories for physicians who qualified for 2017 Advancing Care Information and Extreme and Uncontrollable Circumstances hardship exceptions.
Under the Extreme and Uncontrollable Circumstances policy, Texas physicians whose practices were located in one of the 53 disaster-designated counties due to Hurricane Harvey in 2017 were effectively exempt from participation. For physicians in these areas who did not submit any data, CMS should have automatically applied a score equal to the performance threshold (3 points) and a “neutral payment adjustment,” CMS parlance for no payment penalty, in 2019. Because CMS failed to do this, physicians were applied the full 4-percent payment penalty.
CMS says it has corrected the errors and made changes to 2017 MIPS final scores and payment adjustments for the 2019 payment year. For this reason, TMA strongly recommends all physicians sign in to the QPP portal to review their new information and request a targeted review by Oct. 15 if needed. If you participated in an APM last year, contact your APM administrator about performance feedback specific to your model.
A “targeted review” means CMS will review your information again and make corrections accordingly. If you miss this deadline, there will be no other way to file an appeal. Of note, the targeted review process is different from the regular appeals process for Medicare claims determinations, and requests must go through the avenue described in this CMS guide.
For complete details on how to establish an Enterprise Identity Data Management or EIDM account for the QPP portal, check your information, and/or request a targeted review, refer to the guides in the CMS 2017 Resource Library.
If you have questions, contact the QPP Service Center at (866) 288-8292, or by email at QPP[at]cms[dot]hhs[dot]gov.
For free help, contact the TMF Health Quality Institute. TMF consultants will help you sign in to the QPP portal, walk you through the data, interpret your performance feedback and scoring results, review your payment bonus or penalty, and guide you through the targeted review process.
The Texas Medical Association can also help.
TMA’s practice management consultants provide customized on-site assistance to help you focus on clinical processes, electronic health record optimization, and workflow improvement opportunities necessary for successful MIPS reporting. The in-person assessment also provides assistance with reporting, as well as interpreting MIPS performance feedback to help physicians improve their scoring. TMA Practice Consulting provides services to TMA members at below-market rates. For more information, contact TMA Practice Consulting at (800) 523-8776 or practice.consulting[at]texmed[dot]org.
As always, visit the TMA MACRA Resource Center to stay up to date on the latest information.