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Maintaining MIPS Momentum

Wednesday, November 04 2020

The COVID-19 public health emergency has led many clinicians and practices to redefine priorities, modify procedures, and reallocate resources. While it can be challenging to focus on MIPS during this time of unprecedented uncertainty, continuing to collect and report MIPS data could provide long-term benefits for your practice. Below are some reasons why you should keep the momentum going.

  • CMS has proposed to set the performance threshold to 50 points for PY 2021, a 5-point increase from PY 2020. Looking ahead to PY 2021 and beyond, maintaining your team’s reporting workflows and habits will make future reporting easier. Continuing to focus on collecting data now will help your practice in the future as MIPS requirements evolve.
  • The Extreme and Uncontrollable Circumstances policy may become less universally applicable as policymakers and clinicians adapt to the post-pandemic world. If such a decision is made, this would mean that many practices will be required to report MIPS data in PY 2021 and will need to perform at a higher level than has been required in the past to avoid a penalty. Your practice will be better positioned for success if you don’t have to re-learn and re-implement the processes and workflows needed to collect and report MIPS data.
  • CMS is continuing its gradual implementation of the MIPS Value Pathways (MVPs), beginning as early as 2022. With the MVP framework, CMS intends to align and connect measures and activities across the four MIPS performance categories for different specialties or conditions. While CMS envisions that MVPs will ultimately reduce the MIPS reporting burden, clinicians must be prepared to collect and submit the required data for MVP measures. Because MVPs will build on current MIPS measures, staying current with MIPS reporting that is relevant to your practice area or specialty will position your practice to make a more seamless transition to this new framework.
  • Remember that if you do report data for PY 2020 and receive a final score above 45 points, you may receive a positive payment adjustment in 2022. You can build upon your success in previous years by reviewing your PY 2019 performance results and understanding your areas of strength and weakness.

For the 2020 performance year (PY), CMS is using the Extreme and Uncontrollable Circumstances (EUC) policy to allow clinicians and groups who have been affected by the COVID-19 pandemic to request reweighting of any or all performance categories. For more information on the Quality Payment Program COVID-19 Response, click here. If a practice was prevented from collecting MIPS measures data for an extended period, requesting the EUC exception may be the best option to avoid a penalty.

If you have any questions about your PY 2019 performance feedback, or about MVPs, do not hesitate to contact the QPP Indiana Help Desk.

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