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How to Avoid the MIPS Penalty in 2020

Wednesday, November 04 2020

In the 2020 performance year, MIPS participants need to obtain a minimum of 45 points to prevent a negative payment adjustment in 2022. If you can collect data on one or more MIPS performance categories, there are strategies to help you reach the MIPS performance threshold. Several technical assistance contractors, have developed free resources to help small practices meet the 2020 performance threshold:

Quality Performance Category

  • Select measures from the 2020 Quality Measure List for which your practice can meet the data completeness requirements or measures for which you can obtain data from 70 percent of eligible patients. Consider selecting high-weighted and/or outcome measures to obtain as many points as possible.
  • Review your 2019 performance feedback and note which measures were successful for your practice and which need improvement.
  • Review your specialty measure set and report on six measures in the set. If the set contains fewer than six measures, report on all measures in the set.
  • If possible, consider reporting on MIPS measures that can be collected via telehealth due to the possibility of a decrease in the number of in-person office visits this fall and winter.
  • Consider using multiple submission methods if you cannot find relevant measures. For example, registries may offer additional MIPS measures to report.

Remember that clinicians in small practices (15 or fewer clinicians) automatically receive six points in the quality category if at least one quality measure is reported.

Cost Performance Category

  • You do not need to report any data for the Cost performance category. CMS automatically calculates your cost score based on administrative claims submitted for the entire calendar year.
  • Review your performance feedback from previous years as well as the 2019 Cost Performance Category Fact Sheet to help understand your past performance.
  • Review the 2020 MIPS Summary of Cost Measures and required case minimums to see which cost measures will be scored.
  • Identify your most costly patients and consider taking steps to improve care coordination for these patients.

Promoting Interoperability (PI) Performance Category

  • Some clinician types qualify for automatic re-weighting of the PI category. See if you qualify using the QPP participation status look-up tool.
  • If you are a small practice and have insufficient internet connectivity, decertified EHR technology, or lack of control over the availability of certified EHR technology, you can apply for a PI hardship exception You can also apply if you face extreme and uncontrollable circumstances, such as practice closure, or severe financial distress. Applications must be submitted by December 31, 2020.

Improvement Activities Performance Category

  • Review the complete list of improvement activities and select activities that make the most sense for your practice. Remember to take credit for any activities that you are already doing as part of your current workflow.
  • Be sure to review which activities are still available and which have been removed for this performance year.
  • Small practices can receive full credit for the Improvement Activities performance category when they complete one high-weighted activity or two medium-weighted activities.

As the COVID-19 pandemic continues, small practices may be struggling to reach the 45-point threshold. If you have been severely impacted by the COVID-19 pandemic or other extreme and uncontrollable circumstances, keep in mind that you can apply for an Extreme and Uncontrollable Circumstances Exception. If approved, this exception will re-weight any or all performance categories to help you avoid a negative payment adjustment.

For more information and advice on how to reach 45 points, contact the QPP Indiana Help Desk.


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