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Decoding Submission Methods

Understand the different submission method options available, how they impact the performance categories, and factors to consider before picking a submission method. 

EHR

Registry/QCDR

Claims

CMS Web Interface

CAHPS for MIPS Survey

Attestation 

One Submission Method Per Performance Category

Individual MIPS eligible clinicians, groups, and virtual groups must use one submission method per performance category for the performance year 2018. However, a different submission method could be utilized for each performance category. For instance, Registry submission method could be used to submit data for the Quality category, while EHR submission method could be utilized to submit data for PI (formerly ACI) and IA categories.  

The ability to use multiple submission methods for a single performance category will become available in performance year 2019.

Submission Methods and Performance Categories


Impact of Submission Method On All Performance Categories

EHR, Qualified Registry, Qualified Clinical Data Registry (QCDR), CMS Web Interface (groups of 25 or more),Claims, CAHPS for MIPS survey

Submission methods have the power to influence the Quality category score significantly as different submission methods have different benchmarks for the same measure.

More importantly, not all measures are available via all submission methods.

For the clinicians claiming hardship exception, the PI category weight (25%) will be allocated to Quality category, making it 75% of your MIPS score. It definitely warrants a closer look.

Attestation, EHR, Qualified Registry, QCDR,
CMS Web Interface (groups of 25 or more)


For the Promoting Interoperability category, the scoring is done on a fixed decile scale. 50% performance for any measure for which a numerator and denominator needs to be reported, will earn 50% of the maximum points allocated for that measure.

Submission method has no bearing on the PI category score.

Attestation, EHR, Qualified Registry, QCDR



For Improvement Activities category, clinicians need to complete the activity, document their work, and attest to completing the activity.

The submission method used to attest does not impact the MIPS score, except for the activities that are eligible for bonus points in the PI category if reported via an EHR.

No submission is required. 
Administrative claims used by CMS.  


For the Cost category, CMS will be pulling the data from administrative claims submitted by clinicians for the two measures to be scored in 2018.

The benchmarks for these measures will be developed based on 2018 data, and the performance will be calculated on a decile scale.  

 Submission Methods for Quality - Factors to Consider


As the submission method has a huge impact on the Quality score and thus the MIPS score, following factors need to be considered before picking one. 

REPORTING ENTITY. Eligible clinicians can report as individuals, groups or virtual groups. Certain submission methods are only available to certain reporting entity only.

For instance, Claims submission method is available to only clinicians reporting as individuals, whereas CAHPS for MIPS survey is only available to clinicians reporting as groups. Additionally, CMS Web Interface is only available to groups of 25 or more clinicians. To be able to use CMS Web Interface and CHAPS for MIPS for 2018, you would need to register as a group with CMS by June 30, 2018.

NUMBER OF REQUIRED MEASURES. Most of the providers will need to report 6 quality measures for the full calendar year 2018. But if your specialty measure set has less than six measures available, you will not incur a penalty if you report on all the measures in the measure set. However, you have to pick the submission method that will support all the measures in this set. On the other hand, if a group utilizes CMS Web Interface submission method (only available to groups of 25 or more), the group would need to report all the 14 measures included in the CMS Web Interface and an additional All Cause Hospital Readmission Measure if applicable. Not doing so will negatively impact the Quality score. 

EXCEPTION TO ONE SUBMISSION METHOD RULE. This exception applies to clinicians reporting as a group (and virtual group). Groups are allowed to use two submission methods for the Quality performance category only if they choose to report one quality measure using CAHPS for MIPS Survey through a CMS approved survey vendor. The survey counts as one quality measure only, and can be used in conjunction with any other submission method that a group is using to submit the rest of the quality measures.

AVAILABLE MEASURES. Not all measures are available to report via all submission methods. Some measures are available to report via multiple submission methods, while others are available only for a particular one. The measures for CMS Web Interface are fixed and the groups using this submission method need to report on all the 14 measures. Failure to do will negatively impact the score for Quality category. 

MEASURE BENCHMARKS. The submission method must not be picked just on the basis of available measures, without taking into account the measure benchmarks. The measure benchmarks are determined for each submission method based on the historical data submitted to CMS for that measure using a specific submission method. Resultantly, a given measure has separate benchmarks for all the Submission methods it is available to report under. This results in the difference in points for the measure depending on if it is reported via Claims, Registry, or EHR submission method. Furthermore, a measure could be topped-out for one submission method, but not for other. 

Quality Submission Methods by Reporting Entity


INDIVIDUALGROUPVIRTUAL GROUP
DefinitionSingle NPI tied to a single TIN Set of clinicians (identified by NPI) sharing a TINDifferent TINs
(with 1-10 MIPS eligible clinicians)
coming together with at least one other such TIN to form a Virtual Group
ReportingIndividual dataGroup level dataVirtual group level data
Payment Adjustment Based OnIndividual PerformanceOne payment adjustment based on
group’s performance
One payment adjustment based on
virtual group’s performance
Common Submission MethodsEHR, Registry, QCDREHR, Registry, QCDREHR, Registry, QCDR
Unique Submission MethodsMedicare ClaimsCMS Web Interface (25 or more)CMS Web Interface (25 or more)
CAHPS for MIPS Survey Not ApplicableCan include as 1 quality measureCan include as 1 quality measure
All Cause Hospital Readmission Measure  Not ApplicableApplicable to groups of 16 or more Applicable to virtual groups of 16 or more

Quality Measure Requirements by Submission Method

SUBMISSION METHODAVAILABLE FORMEASURES TO REPORT
ClaimsIndividuals only6 Measures

Qualified Registries & QCDRsIndividuals, Groups, Virtual Groups6 Measures + All Cause Readmission Measure
for Groups of 16 or more (if applicable)

EHRIndividuals, Groups, Virtual Groups6 Measures + All Cause Readmission Measure
for Groups of 16 or more (if applicable)

CMS Web InterfaceOnly groups and virtual groups  of 25 or more14 Measures + All Cause Readmission Measure
(if applicable) 

CAHPS for MIPSGroups and Virtual GroupsCounts as one quality measure if reported
Can be used in combination with
one other submission method 

Picking Submission Method

The decision of picking a submission method should not be driven by only the number of measures available, or by the options offered by your EHR vendor, or by your organization’s traditional reporting method. Each submission method offers some unique advantages. But the decision to pick a submission method should be well thought out in combination with the measures and your expected performance rate to excel in the Quality category.

You need to consider:
- The measures that are relevant to your practice
- The benchmarks (availability/non-availability) for selected measures for selected submission method
- If a chosen measure is topped out
- Performance rate achievable for the selected measures
- The bonus points available for chosen measures (Outcome, High Priority, and Patient experience measures earn you additional bonus points)
- If the manner you chose to report will meet the end-to-end reporting bonus requirements.

MyMipsScore brings together all these pieces in one place for you to aid in decision making. The MIPS Score Simulator feature enables you to run what-if scenarios with your data to help figure out the best option for your clients. Furthermore, you can see instantly how a change in a quality measure performance rate impacts MIPS payment adjustment. 

MIPS Score Simulator

Find the best measures, performance rates, and submission method to help maximize MIPS score for your clients

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