The data submission period for Medicare’s 2019 Quality Payment Program (QPP) is under way and closes on March 31. If you haven’t started the process, now is the time to ensure your data for the Merit-Based Incentive Payment System (MIPS) is in order and submit it in time to make corrections by the deadline, if needed.
In general, physicians and other health care professionals who are MIPS-eligible must submit data to the Centers for Medicare & Medicaid Services (CMS) every year. Data submitted for a given performance year affects your Medicare payment two years later.
At stake for the 2019 QPP performance year is a 7% cut to your Medicare payments in 2021. Physicians who plan to submit data by qualified registry, qualified clinical data registry, electronic health record, web interface, survey vendor, and/or self-attestation must complete there reporting by March 31.
(Note that physicians who reported quality data through Medicare Part B claims should have submitted data throughout 2019 and must have completed their reporting by Feb. 29.)
Scoring for 2019 covers a 0-100 point scale, which is based on your performance in four MIPS categories: quality, promoting interoperability, cost, and improvement activities. No data submission is required for the cost category.
For the 2019 performance year, you will need a MIPS final score of at least 30 points to avoid a cut. To receive an incentive payment, your practice must score between 30.01 and 74.99. A score between 75 and 100 will mean an incentive payment, plus an additional bonus for exceptional performance.
You or your vendor may submit data via the QPP portal at any time until the deadline. Immediately upon submission, CMS will provide you with preliminary scores. It will issue final 2019 MIPS performance scores and 2021 payment adjustment information in July.
If you are working with a vendor to submit MIPS data on your behalf, the Texas Medical Association encourages you to sign in to the QPP portal to review your MIPS data for accuracy. If you identify data errors, work with your vendor as soon as possible because CMS will not allow resubmissions after the deadline.
For MIPS guidance and support, here’s how TMA and others can help:
- To find out if you are required to participate in 2019 MIPS, check the QPP lookup tool to confirm your final eligibility. When you review your profile, take note of any designation assigned to you under “other reporting factors” (e.g., small practice, rural practice, health professional shortage area, facility-based) and learn what these factors mean to your practice. If you’re not required to report but wish to participate in MIPS, refer to the opt-in and voluntary reporting fact sheet and election toolkit (zip file).
- For 2019 MIPS data requirements and guidance, refer to the QPP Resource Library, CMS’ FAQs, CME modules, and/or short video series: introduction and overview of 2019 data submission, file upload and quality scoring, web interface, and manual attestation of improvement activities and promoting interoperability measures.
- To review what you need to know about Medicare audits, refer to the 2019 MIPS data validation criteria (zip file).
- For free comprehensive education and QPP tips, developed with TMA input, visit the MACRA QPP Resource Center by the Physicians Advocacy Institute.
- To get free technical assistance on how to submit your 2019 MIPS data, contact QPP experts at the TMF Health Quality Institute.
- For personalized quality improvement services and tailored practice support to help your practice succeed in the QPP, contact TMA Practice Consulting.
If you were in a MIPS Alternative Payment Model (APM) in 2019, you will be scored under the APM scoring standard within MIPS. Contact your APM administrator for details and ask if you need to submit any MIPS data.
If you were in an advanced APM in 2019, contact your APM administrator to ask whether you achieved qualifying APM participant (QP) status or partial QP status under the Medicare Option or new All-Payer Advanced APM Option. Refer to the QP Methodology Fact Sheet (zip file) for details about these designations. If you didn’t achieve either status, you’ll likely default into MIPS unless you don’t meet eligibility criteria.
For answers to your MIPS and APM questions, contact the QPP Service Center at (866) 288-8292 or by email at QPP@cms.hhs.gov. To avoid long wait times, call during non-peak hours, which are before 9 am and after 1 pm CT.
Lastly, to help inform our ongoing advocacy to simplify and improve the QPP, email TMA your story and tell us your challenges with the program and recommendations for improvements. For more information, visit the TMA MACRA Resource Center.