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MIPS Question and Answer Town Hall Event for Solo and Small Group

Practices

March QPP SURS LAN Webinar Questions and Answers

March 19 and 21, 2019

Resources:

• For free MIPS Technical Assistance, contact: o FL, GA, NC, SC: Alliant GMCF

▪ Phone: 844-777-8665 ▪ Email: QPPSURS@ALLIANTQUALITY.ORG ▪ Submit request: https://www.surveymonkey.com/r/QPPHelpForm ▪ Website: http://www.alliantquality.org/

o AR, MO, OK, TX, PR, LA, MS, CO, KS: TMF Health Quality Institute ▪ Phone: 844-317-7609 ▪ Email: QPP-SURS@tmf.org ▪ Submit request: https://tmf.org/QPP/Request-Help ▪ Live chat: https://chat.tmf.org:8443/ECCChat/chat.html ▪ To join TMF’s Learning and Action Network: https://www.tmfqin.org/qpp

o AL, TN: QSource

▪ Phone: 844-205-5540

▪ Email: techassist@qsource.org

o NJ, PA, DE, WV: Quality Insights

▪ Phone: 877-497-5065

▪ Email: qpp-surs@qualityinsights.org

▪ Website: https://www.qualityinsights.org

o NY, MD, DC, VA: IPRO

▪ Phone: 866-333-4702

▪ Email: ny-qppsupport@atlanticquality.org (change state code depending on the

state you practice in)

▪ Submit request: https://ipro.org/for-providers/medicare-qpp/req-tech-assist

o WA, ID: Qualis Health

▪ Phone: 877-560-2618

▪ Email: QPP-SURS@qualishealth.org

▪ Website: http://medicare.qualishealth.org/projects/QPP-resource-center

o MT, WY, UR, NV, OE, AK: Network for Regional Healthcare Improvement (NRHI)

▪ Email: QualityPaymentHelp@mpqhf.org

o ND, SD, NE, IA: Telligen

▪ Phone: 844-358-4021

▪ Email: qpp-surs@telligen.com

▪ Submit request: https://telligenqpp.com/contact/

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o MN, WI, MI, IL, IN, OH, KY: Altarum

▪ Email: qppinfo@altarum.org

o ME, NH, MA, VT, RI, CT: Healthcentric Advisors

▪ Email: NEQPPSURS@healthcentricadvisors.org

o NM, AZ, CA, HI: Health Services Advisory Group (HSAG)

▪ Phone: 844-472-4227

▪ Email: HSAGQPPSupport@hsag.com

• General QPP Information:

o QPP CMS Website: https://qpp.cms.gov/

o QPP CMS Resource Library: https://qpp.cms.gov/about/resource-library

o Locate your QPP SURS Technical Assistance Contractor:

https://qpp.cms.gov/about/small-underserved-rural-practices

o QPP Participation Status Tool: https://qpp.cms.gov/participation-lookup

o Technical Assistance Resource Guide: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/25/TA%20Resource%20Guide%202017%2004%20

24_Remediated.pdf

o QPP Access User Guide: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/335/2018%20QPP%20Access%20User%20Guide.zi

p

• Hardship Exceptions: https://qpp.cms.gov/mips/exception-applications

• 2019 Claims Data Submission Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/444/2019%20Claims%20Data%20Submission%20Fact%20S

heet.pdf

• 2018 Promoting Interoperability Measure Specifications: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/139/2018-MIPS%20Promoting%20Interoperability-

Measure-Specifications.zip

• 2019 Promoting Interoperability Performance Category Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/487/2019%20MIPS%20Promoting%20Interoperability%20

Fact%20Sheet.pdf

• 2018 MIPS Scoring 101 Guide: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/179/2018%20MIPS%20Scoring%20Guide_Final.pdf

• Medicare Risk Adjustment Eligible CPT/HCPCS Codes: https://www.cms.gov/Medicare/Health-

Plans/MedicareAdvtgSpecRateStats/Risk-Adjustors-Items/CPT-HCPCS.html

• 2019 Participation and Eligibility Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/349/2019%20MIPS%20Participation%20and%20Eligibility

%20Fact%20Sheet.pdf

• 2019 Cost Performance Category Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/351/2019%20Cost%20Performance%20Category%20Fact

%20Sheet.pdf

• 2019 Medicare Part B Claims Measures Specifications and Supporting Documents: https://qpp-

cm-prod-

content.s3.amazonaws.com/uploads/338/2019%20Medicare%20Part%20B%20Claims%20Meas

ure%20Specifications%20and%20Supporting%20Documents%C2%A0.zip

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• 2019 Quality Benchmarks: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/342/2019%20MIPS%20Quality%20Benchmarks.zip

• 2019 Facility-Based Measurement Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/454/2019%20Facility-

Based%20Measurement%20Fact%20Sheet_Final.pdf

• 2019 Qualified Clinical Data Registries (QCDRs) Qualified Posting: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/347/2019%20QCDR%20Qualified%20Posting_Final_v3.xlsx

• 2019 Qualified Registries Qualified Posting: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/348/2019%20Qualified%20Registry%20Posting_Final_v1.0

.xlsx

• EMA Fact Sheet: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/164/2018%20QPP%20EMA.zip

• 2019 Improvement Activities Inventory: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/346/2019%20Improvement%20Activities.zip

• Alternative Payment Models (APMs): https://qpp.cms.gov/apms/overview

• Explore Measures Tool: https://qpp.cms.gov/mips/explore-measures/quality-measures

• LAN Webinar Recordings, Transcripts, Q&As, and Slides:

https://qppsurs.wordpress.com/resources/

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Questions and Answers March 19 & 21, 2019

General 1. May we have a very basic description of MIPS for our new quality professionals?

CMS is required by law to implement a quality payment incentive program, referred to as the

Quality Payment Program, which rewards value and outcomes in one of two ways: Merit-based

Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). Under

MIPS, clinicians are included if they are an eligible clinician type and meet the low volume

threshold, which is based on allowed charges for covered professional services under the

Medicare Physician Fee Schedule (PFS), the number of Medicare Part B patients who are

furnished covered professional services under the Medicare Physician Fee Schedule, and the

number of covered professional services provided to Part B-enrolled patients. Performance is

measured through the data clinicians report in four areas - Quality, Improvement Activities,

Promoting Interoperability (formerly Advancing Care Information), and Cost. CMS designed MIPS

to update and consolidate previous programs, including the Medicare Electronic Health Records

(EHR) Incentive Program for Eligible Clinicians, Physician Quality Reporting System (PQRS), and

the Value-Based Payment Modifier (VBM).

2. How do I know if I am signed up for MIPS?

You do not sign up for MIPS. CMS determines clinician eligibility based on each combination of

individual NPI and Tax Identification Number (TIN). To find out your eligibility status and see if

you are required to participate in the MIPS program, please check the QPP NPI Lookup Tool at

https://qpp.cms.gov/participation-lookup.

3. What are the changes for 2019 that will affect small practices?

For the 2019 performance year, small practices can submit quality measures using Medicare Part

B claim measures both at the individual and the group level. In addition, the small practice bonus

will now be added to the Quality performance category, rather than the MIPS final score

calculations. This means that six bonus points are added to the numerator of the Quality

performance category for MIPS eligible clinicians in small practices who submit at least one

quality measure. In 2019, CMS continues to award small practices three points for submitted

quality measures that do not meet the data completeness requirements. For the 2019 MIPS

performance period, CMS has added a third component to the low-volume threshold as noted

below. Therefore, clinicians, groups and APM Entities are excluded from MIPS if they:

1. Bill less than or equal to $90,000 in Medicare Part B allowed charges for covered

professional services payable under the Physician Fee Schedule (PFS); or

2. Provide covered professional services for 200 or fewer Part B-enrolled patients; or

3. Provide 200 or fewer covered professional services to Part B-enrolled patients. This is a

new element beginning in the 2019 MIPS performance period.

In addition, beginning with the 2019 MIPS performance period, if an individual eligible clinician,

group or APM Entity exceeds at least one but not all three of the low-volume threshold criteria,

and elects to report on applicable measures and activities under MIPS by electing to opt-in, then

the individual MIPS eligible clinician, group, or APM Entity will be considered MIPS eligible and

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will be assessed in the same way as all other MIPS eligible clinician(s). Clinicians and groups that

elect to opt-in will receive a MIPS payment adjustment based on their 2019 performance. Please

be advised that the decision to elect to opt-in is binding and irreversible; thus, clinicians

considering this option should explore program requirements, measures and activities to ensure

that it is applicable and meaningful for them.

4. What is the site to add a physician for MIPS? We cannot find it on the QPP site.

When you sign into the QPP Portal at https://qpp.cms.gov/login, you will be able to see who

CMS has determined as part of your practice. You do not have the ability to change the provider

list. If you believe there is an error, you can contact the QPP helpdesk at 1-866-288-8292. If a

new clinician is joining your practice, the clinician should register their HARP account under your

practice’s Tax Identification Number (TIN).

5. Hardship exemptions need to be applied for yearly, correct? We applied for one in 2018, so I am

assuming we have to apply again in 2019. Is the application available now?

In most cases, you need to apply for hardship exemptions each year. Applications are not

available yet. They will be available closer to the end of 2019. There are also certain situations

where submitting a hardship application is not required. If a MIPS-eligible clinician is considered

Special Status, they will be automatically reweighted. Special Status clinicians include hospital-

based MIPS eligible clinicians, physician assistants, nurse practitioners, clinical nurse specialists,

certified registered nurse anesthetists, non-patient facing clinicians and Ambulatory Surgical

Center-based MIPS-eligible clinicians. More information on hardship exceptions can be found at

https://qpp.cms.gov/mips/exception-applications.

6. How do we remove clinicians who no longer work for us and have been gone over a year?

When you sign into the QPP Portal, you will be able to see who CMS has determined as part of

your practice. You do not have the ability to change the provider list manually. If you believe

there is an error, you can contact the QPP helpdesk at 1-866-288-8292 to address the error.

7. We are a hospital that just hired two providers for the first time as of 3/1/19. They have never

participated in MIPS before. Where do we begin?

You can start by checking your providers’ eligibility for MIPS by entering their National Provider

Identifiers (NPIs) into the QPP NPI Lookup Tool. The Lookup Tool can be found at

https://qpp.cms.gov/participation-lookup. There are several resources available in the QPP

resource library including the MIPS Participation and Eligibility Fact Sheet, the 2019 MIPS Quick

Start Guide and QPP Access User Guide. CMS also has data submission videos posted on their

CMS YouTube channel that will make participating for the first time easier. Please visit

https://qpp.cms.gov/about/resource-library to access all the CMS Quality Payment Program

resources.

If you have any questions or need assistance with participating in the MIPS program, we

encourage you to reach out to your region’s Technical Assistance Contractor for free technical

assistance. Information for your region’s Technical Assistance Contractor can be found at

https://qpp.cms.gov/about/small-underserved-rural-practices.

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Eligibility 8. Do we start by entering all our providers (i.e. hospital and RHC-based) TIN and NPI on

qpp.cms.gov to determine eligibility?

CMS determines clinician eligibility based on each combination of individual NPI and Tax

Identification Number (TIN). You can enter your providers’ NPIs into the NPI Lookup Tool to

determine their eligibility to participate in MIPS. The Lookup Tool can be found at

https://qpp.cms.gov/participation-lookup. CMS tries to update the QPP NPI Lookup Tool as

quickly as possible after the conclusion of the determination period. The MIPS determination

period for 2019 consists of the two 12-month segments:

• Segment #1: A 12-month segment beginning on October 1, 2017 and ending on

September 30, 2018, plus a 30-day claims run out; and

• Segment #2: A 12-month segment beginning on October 1, 2018 and ending on

September 30, 2019. Segment #2 does not include a claims run out period.

You can also reach out to your regional Technical Assistance Contractor for help determining

your MIPS eligibility in 2019. You can locate your region’s Technical Assistance Contractor at

https://qpp.cms.gov/about/help-and-support.

9. We have practitioners that left our practice over a year ago that still show as part of our group.

If they are not eligible to report, will they count against our number as a small group which is

how we report? Will we be bumped out of a small practice if we have a list of 17 people, 3 of

whom have left?

A small practice is defined as a Tax ID Number (TIN) associated with 15 or fewer eligible

clinicians (NPIs). You can verify how your practice is defined using the QPP NPI Lookup Tool at

https://qpp.cms.gov/participation-lookup. If you believe there is an error, you can contact the

QPP helpdesk at 1-866-288-8292. CMS looks at each combination of individual NPI and Tax

Identification Number (TIN) to make eligibility determinations. Please see the response to

question #8 for the MIPS determination period segments. When you sign into the QPP Portal,

you will be able to see who CMS has determined as part of your practice. Please note if the

clinicians were in your practice during the MIPS performance period, their data should be

included when reporting as a group. If they left prior to the reporting period, they do not need to

be included in your submission and they will not count against your status as a small practice.

We encourage you to reach out to your region’s Technical Assistance Contractor for additional

support. You can locate your local Technical Assistance Contractor at

https://qpp.cms.gov/about/small-underserved-rural-practices.

10. We hired a physician assistant this year, she will begin seeing patients next month, so we need

to report on her this year, correct?

If the physician assistant meets the low volume threshold and is determined as eligible, then yes.

You can determine the new provider’s eligibility status using the QPP Lookup tool at

https://qpp.cms.gov/participation-lookup. Please be sure to check your providers’ eligibility

status after each determination period to confirm their MIPS eligibility status. CMS tries to

update the QPP NPI Lookup Tool as quickly as possible after the conclusion of the determination

period. Please see the response to question #8 for the MIPS determination period segments.

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You can also reach out to your regional Technical Assistance Contractor for help determining

your MIPS eligibility in 2019. You can locate your region’s Technical Assistance Contractor at

https://qpp.cms.gov/about/help-and-support.

11. One of our providers is showing ineligibility as a hospital-based non-patient facing physician,

however he has been with us for 2 years now and qualifies by all definitions. Should I upload his

data anyway?

CMS defines hospital-based clinicians as clinicians that furnish 75% or more of his or her covered

professional services identified by the Place of Service (POS) codes used in the HIPAA standard

transaction as an off-campus outpatient hospital (POS19), inpatient hospital (POS21), on-campus

outpatient hospital (POS 22), or emergency room settings (POS 23). If you choose to report as a

group, the group will have its performance assessed and scored across the TIN, which should

include items and services furnished by individual NPIs within the TIN who are not required to

participate in MIPS individually. Thus, their data should be still uploaded as part of the group.

If you were planning to upload the physician’s data as an individual, submitting their data would

not be necessary if the physician is ineligible. However, eligibility status might also change

throughout the year, so please check the physician’s eligibility status after each determination

period to confirm their MIPS eligibility status. CMS tries to update the NPI Lookup Tool as quickly

as possible after the conclusion of the determination period. Please see the response to question

#8 for the MIPS determination period segments. In addition, beginning with the 2019 MIPS

performance period, if an individual eligible clinician, group or APM Entity exceeds at least one

but not all three of the low-volume threshold criteria, and elects to report on applicable

measures and activities under MIPS by electing to opt-in, then the individual MIPS eligible

clinician, group, or APM Entity will be considered MIPS eligible and will be assessed in the same

way as all other MIPS eligible clinician(s). Clinicians and groups that elect to opt-in will receive a

MIPS payment adjustment based on their 2019 performance. Please be advised that the decision

to elect to opt-in is binding and irreversible; thus, clinicians considering this option should explore

program requirements, measures and activities to ensure that it is applicable and meaningful for

them.

Another option for the hospital-based provider may be facility-based measurement. The 2019

MIPS performance year is the first year that CMS will apply facility-based measurement. CMS will

automatically apply facility-based measurement to the Quality and Cost performance category

scores if MIPS eligible clinicians, groups, and virtual groups are determined to be facility-based.

Therefore, you will not need to submit any data for the Quality performance category to be

considered for facility-based measurement. For more information on facility-based

measurement, please see the 2019 Merit-Based Incentive Payment Program (MIPS) Facility-

Based Measurement Fact Sheet at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/454/2019%20Facility-

Based%20Measurement%20Fact%20Sheet_Final.pdf.

12. What happens if the eligible clinician is only with us from January 1st to March 31st? We are a

small group, so we do individual reporting.

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Because clinicians come and go, and eligibility status might change throughout the year, please

check your eligibility status using the QPP NPI Lookup Tool after each determination period to

confirm your MIPS eligibility status. The QPP NPI Lookup Tool provides eligibility information on

each individual TIN/NPI combination and can be found at https://qpp.cms.gov/participation-

lookup. CMS tries to update the QPP NPI Lookup Tool as quickly as possible after the conclusion

of the determination period. Please see the response to question #8 for the MIPS determination

period segments. You can also reach out to your regional Technical Assistance Contractor for

help determining your MIPS eligibility in 2019. You can locate your region’s Technical Assistance

Contractor at https://qpp.cms.gov/about/help-and-support.

13. What are the changes to the reporting eligibility requirements?

For the 2019 MIPS performance period, CMS has added a third component to the low-volume

threshold as noted below. Therefore, clinicians, groups and APM Entities are excluded from

MIPS if they:

1. Bill less than or equal to $90,000 in Medicare Part B allowed charges for covered

professional services payable under the Physician Fee Schedule (PFS); or

2. Provide covered professional services for 200 or fewer Part B-enrolled patients; or

3. Provide 200 or fewer covered professional services to Part B-enrolled patients. This is a

new element beginning in the 2019 MIPS performance period.

For the 2019 performance year, MIPS eligible clinicians include all the same types as in 2018 but

with the addition of clinical psychologists, physical therapists, occupational therapists, speech-

language pathologists, audiologists, and registered dieticians or nutrition professionals.

In 2019, clinicians who do not meet the low-volume threshold may voluntarily report, which

involves submitting data to CMS and receiving performance feedback, but not receiving a MIPS

payment adjustment. Beginning with the 2019 MIPS performance period/2021 MIPS payment

year, if an individual eligible clinician, group or APM Entity exceeds at least one but not all of the

low-volume threshold criteria and elects to report on applicable measures and activities under

MIPS by electing to opt-in, then the individual MIPS eligible clinician, group or APM Entity will be

considered MIPS eligible clinicians and will be assessed in the same way as all other MIPS eligible

clinician(s) for the applicable payment year. Clinicians and groups that elect to opt-in to MIPS are

subject to the same requirements as MIPS-eligible clinicians and will receive a MIPS payment

adjustment based on their 2019 performance. Please be advised that the decision to elect to opt-

in is binding and irreversible; thus, clinicians considering this option should explore program

requirements, measures and activities to ensure that it is applicable and meaningful for them.

To find out your eligibility status, including whether or not you can opt-in, please check the QPP

NPI Lookup Tool at https://qpp.cms.gov/participation-lookup. CMS tries to update the QPP NPI

Lookup Tool as quickly as possible after the conclusion of the determination period. The MIPS

determination period for 2019 consists of the two 12-month segments:

• Segment #1: A 12-month segment beginning on October 1, 2017 and ending on

September 30, 2018, plus a 30-day claims run out; and

• Segment #2: A 12-month segment beginning on October 1, 2018 and ending on

September 30, 2019. Segment #2 does not include a claims run out period.

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14. How does one disenroll?

Clinicians that are determined to be MIPS eligible and exceed the low-volume threshold, or

decide to opt-in, are required to participate in MIPS for the corresponding performance. year.

If an eligible clinician or group has the option to opt-in to MIPS or voluntarily report and they do

nothing, then they will be excluded from MIPS and will not receive a positive or negative MIPS

payment adjustment. If an eligible clinician or group chooses not to opt-in to MIPS but instead

chooses to voluntarily report measures and activities at the individual level or group level, then

that individual eligible clinician or group will receive performance feedback, but not be subject to

a MIPS payment adjustment.

15. I have a new emergency department physician who is wondering what she is required to submit.

She was required to submit when she was part of a larger facility, but I think she may be exempt

to do so through our facility.

You can check the providers’ eligibility to participate in MIPS using the QPP NPI Lookup Tool. The

Lookup Tool can be found at https://qpp.cms.gov/participation-lookup. If the clinician is

required to report, he/she can find measures to report using the Explore Measures Tool at

https://qpp.cms.gov/mips/explore-measures/quality-measures. Please also note that the 2019

MIPS performance year is the first year that CMS will apply facility-based measurement. CMS will

automatically apply facility-based measurement to the Quality and Cost performance category

scores if MIPS eligible clinicians, groups, and virtual groups are determined to be facility-based.

Therefore, you will not need to submit any data for the Quality performance category to be

considered for facility-based measurement. For more information on facility-based

measurement, please see the 2019 Merit-Based Incentive Payment Program (MIPS) Facility-

Based Measurement Fact Sheet at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/454/2019%20Facility-

Based%20Measurement%20Fact%20Sheet_Final.pdf. Your local Technical Assistance Contractor

can help you understand your reporting requirements. Information for your region’s Technical

Assistance Contractor can be found at https://qpp.cms.gov/about/small-underserved-rural-

practices.

16. What is the low volume threshold for reporting eligibility in 2019?

For the 2019 MIPS performance year, clinicians, groups, and APM entities would are required to

report if they exceed these three criteria:

• Bill $90,000 in Medicare Part B allowed charges for covered professional services

payable under the Physician Fee Schedule (PFS); and

• Provide covered professional services for 200 Part B-enrolled patients; and

• Provide 200 covered professional services to Part B-enrolled patients. This is a new

element beginning in the 2019 MIPS performance period.

You can check your eligibility using the QPP NPI Lookup tool at

https://qpp.cms.gov/participation-lookup.

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Reporting 17. Is there a benefit to report an individual provider’s data if it is not required (i.e. they started

7/1/18)?

For the 2018 MIPS performance period, there is no financial benefit to report an individual

provider’s data if they were not eligible, as they would not be subject to a MIPS payment

adjustment. However, a provider could have reported voluntarily, which would allow them to get

a feel for the MIPS Program, become familiar with data submission and reporting, and view their

performance results, without being subject to a payment adjustment. This will be beneficial

should they become eligible in the future.

Beginning with the 2019 MIPS performance period/2021 MIPS payment year, if an individual

eligible clinician, group, or APM Entity exceeds at least one but not all three of the low-volume

threshold criteria and elects to report on applicable measures and activities under MIPS by

electing to opt-in, then the individual MIPS eligible clinician, group or APM Entity will be

considered MIPS eligible clinicians and will be assessed in the same way as all other MIPS eligible

clinician(s) for the applicable payment year. If an eligible clinician or group chooses not to opt-in

to MIPS but instead chooses to voluntarily report measures and activities at the individual level

or group level, then that individual eligible clinician or group will not be subject to a MIPS

payment adjustment. Clinicians and groups that elect to opt-in will receive a MIPS payment

adjustment based on their 2019 performance. Please be advised that the decision to elect to opt-

in is binding and irreversible; thus, clinicians considering this option should explore program

requirements, measures and activities to ensure that it is applicable and meaningful for them.

You can reach out to your local Technical Assistance Contractor to discuss the possibility of

opting-in. You can locate your Technical Assistance Contractor at

https://qpp.cms.gov/about/help-and-support.

18. The speaker said all the providers in the group need to submit for the same quality measures.

We are an Otolaryngology office. If the physician and the audiologist are both reporting, some

of the measures cannot be reported by the audiologist since they don't treat nose or throat. Any

advice on this? Do both need to report for the same Improvement Activities? And do we need to

report PI for each provider separately?

If reporting as a group, and you are reporting data via EHR, registry, or qualified clinical data

registry, the numerator and denominators for the quality measures will be aggregated across

the providers in the group. If some measures do not apply to some of the clinicians, they do not

have to focus on those measures.

However, you must consider the data completeness requirement of 60% and the minimum case

volume requirement of 20 cases. If the data completeness requirement is not met due to not all

clinicians performing the same measure, your performance score may be limited. If you are a

small practice (less than 15 clinicians), please note that for any measure submitted for the

Quality performance category that does not meet the data completeness requirement, you will

automatically receive only three points each. In addition, if you choose to submit as a group, all

of the performance data for the clinicians in the group must be aggregated into one submission.

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CMS will then score the top six performing measures included in the data submission.

Note that clinicians have the option to report both as individuals and as a group, and they will

get credit for whichever reporting option gives them the highest final score.

For the Improvement Activities category, if at least one clinician performed the activity, the

group can attest to that activity. Similarly, the Promoting Interoperability (PI) performance

category can be reported for the whole group rather for individual clinicians.

Your local Technical Assistance Contractor can assist you with finding measures to report. You

can locate your region’s Technical Assistance Contractor at https://qpp.cms.gov/about/small-

underserved-rural-practices.

19. What is the reporting period – 90 days or 1 year?

For the Promoting Interoperability and Improvement Activities categories, the reporting period is

at least 90-consecutive days. The reporting period for the Quality and Cost categories is the full

year, from January 1, 2019 to December 31, 2019.

20. What differences are there in 2019 reporting requirements compared to 2018?

In 2019, the Quality category makes up 25% of your final MIPS score. Eligible clinicians must

select six individual measures (one of the measures must be an outcome measure or a high-

priority measure) for the Quality category. If less than six measures apply, report each applicable

measure. Eligible clinicians also have the choice to choose their quality measures from a

specialty-specific set of measures. There are a few small practice-specific changes to the Quality

category:

• The small practice bonus will now be added to the Quality performance category, rather

than the MIPS final score calculation.

• Six bonus points will be added to the Quality category for small practice clinicians who

submit data on at least one quality measure.

• Medicare Part B claims measures can only be submitted by clinicians in a small practice,

whether participating individually or as a group.

In 2019, the Improvement Activities category makes up 15% of your final score. To report, select

Improvement Activities and attest “yes” to completing them. The activity weights remain the

same with medium-weighted activities being worth 10 points and high-weighted activities being

worth 20 points. Small practices, non-patient facing clinicians, and clinicians located in rural or

Health Professional Shortage Areas (HPSAs) continue to receive double-weight and report on no

more than 2 activities to receive the highest score. Also, the Improvement Activities bonus was

removed for 2019.

In 2019, the Cost category makes up 15% of your final score. For 2019, eight episode-based

measures were added. For the Cost category, there is no reporting requirement and no

improvement scoring. In 2019, in addition to the case minimum of 20 for the Total per Capita

Cost measure and 35 for the Medicare Spending Part B measure, there is also a case minimum of

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10 for procedural episodes and a case minimum of 20 for acute inpatient medical condition

episodes.

In 2019, the Promoting Interoperability category makes up 25% of your final MIPS score. Starting

with the 2019 performance year, MIPS eligible clinicians must use 2015 edition CEHRT (unless

they apply for a hardship exception as a solo practitioner or small practice). Also in 2019, there is

new performance-based scoring at the individual measure level and 100 points make up the total

category score. MIPS eligible clinicians must report the required measures under each Objective

or claim the exclusions if applicable.

For more information on changes in 2019, please see the 2019 QPP Final Rule Overview

Factsheet.

21. Can you attest in two different states?

CMS looks at each combination of individual NPI and Tax Identification Number (TIN) to make

eligibility determinations. Therefore, if a clinician has two practices that are in different states

that are both deemed eligible by CMS, the clinician would report to the MIPS program for both

practices. To determine if you are eligible for the MIPS program, please enter your NPI at

https://qpp.cms.gov/participation-lookup. If you have further questions regarding reporting for

practices in different states, your local Technical Assistance Contractor will be your best resource.

You can locate your region’s Technical Assistance Contractor at

https://qpp.cms.gov/about/small-underserved-rural-practices.

22. Help me understand individual vs. group reporting. My provider (practice owner) is eligible. His

newer employed provider is not. The QPP Help Desk said I can individually attest and group

attest, and Medicare will determine the best option for us. But will my ineligible provider's data

negatively impact group reporting?

When eligible for reporting as an individual, group or both, how you report is a choice you can

make based on your specific situation. An individual is defined as a single clinician, identified by

their individual NPI tied to a single TIN. If you report only as an individual, you'll report measures

and activities for the practice under which you are MIPS-eligible and be assessed across all four

performance categories at the individual provider level. Your payment adjustment will be based

on your final score derived from the four MIPS performance categories.

A group is defined as a single TIN with two or more clinicians (at least one clinician within the

group must be MIPS eligible) as identified by their NPI, who have reassigned their Medicare

billing rights to a single TIN. If you report only as a group, you must meet the definition of a

group at all times during the performance period and aggregate the group’s performance data

across the four MIPS performance categories for a single TIN. Each MIPS-eligible clinician in the

group will receive the same payment adjustment based on the group's performance across all

four MIPS performance categories.

MIPS-eligible clinicians can report data as an individual and as part of a group under the same

TIN. In this instance, the clinician will be evaluated across all four MIPS performance categories

on their individual performance and on the group’s performance, with a final score calculated for

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each evaluation. The clinician will receive a payment adjustment based on the higher of the two

scores.

A group electing to submit data at the group level will have its performance assessed and scored

across the TIN, which should include items and services furnished by individual NPIs within the

TIN who are not required to participate in MIPS. Excluded clinicians are still part of the group,

and therefore, would be considered in the group’s score. However, the MIPS payment

adjustments would only apply to payments for covered professional services furnished by MIPS

eligible clinicians. The adjustments would not apply to the excluded clinicians. Any individual

provider (i.e., NPI) excluded from MIPS because they are identified as new Medicare-enrolled,

QP, or partial QP (and choose not to participate) would not receive a MIPS payment adjustment,

regardless of their MIPS participation.

23. I have heard that Retina has enough quality reporting categories to meet the six that are

required. How many patients would we have to enter into the IRIS registry to get the maximum

credit? What is the minimum number of patients I can enter to get the extra credit for doing all

the outcomes? I would like to do all patients for four measures and a limited amount for the

other two.

You must meet the data completeness requirement for the Quality category by submitting at

least 60% of your eligible cases for a given measure for the 12-month period. You would need to

have at least 20 cases in your denominator and report on greater than 60% of your applicable

cases for each measure during the reporting period. If you are a small practice (less than 15

clinicians), please note that for any measure submitted for the Quality performance category

that does not meet the data completeness requirement, you will automatically receive only three

points each.

24. We use a Registry to report. Is there a better way to do this?

In addition to registries, MIPS eligible clinicians may also submit as an individual or group via

Medicare Part B claims (for the Quality performance category, if they are in a small practice),

directly through their EHR, logging-in to the QPP Portal and uploading their performance data,

and by logging-in to the QPP Portal and attesting. However, not all measures are eligible for all

submission methods. Be sure to confirm that the measures you would like to submit data for

available for your selected submission method by checking the measure specifications available

in the QPP Resource Library at https://qpp.cms.gov/about/resource-library.

Please reach out to your region’s Technical Assistance Contractor for help deciding which

reporting option is the best for you. Information for your region’s Technical Assistance

Contractor can be found at https://qpp.cms.gov/about/small-underserved-rural-practices.

Claims Reporting 25. Will there be claims reporting submission available for 2020 for small practices?

In 2019, CMS does allow Medicare Part B claims submissions for the quality category for both

individual clinicians and small groups of 15 or fewer clinicians. CMS evaluates each QPP

performance year independently and the 2020 final rule is not available yet.

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26. Are category II codes the best way to flag the quality measures we provide? Our structured data

boxes don’t seem to be captured well.

This likely depends on how you choose to submit your quality data. The category II codes are

typically Quality Data Codes (QDCs) appended to applicable Part B claim line item submissions

for applicable quality measures. If you are submitting through claims, use your CPT II and correct

Healthcare Common Procedure Coding System (HCPCS) Quality Codes. Medicare Risk Adjustment

Eligible CPT/HCPCS Codes can be found at https://www.cms.gov/Medicare/Health-

Plans/MedicareAdvtgSpecRateStats/Risk-Adjustors-Items/CPT-HCPCS.html.

27. Our EMR vendor doesn’t seem to know what category II scores are. If that’s the case, how do we

capture them?

The category II codes are typically Quality Data Codes (QDCs) appended to applicable Part B

claim line item submissions for applicable quality measures. To collect and submit quality data

through Medicare Part B Claims, you will attach QDCs to your Medicare Part B claims throughout

the 2019 performance year. Please note that the last day for submitting 2019 Medicare Part B

claims with QDCs for the 2019 performance period is determined by your Medicare

Administrative Contractor (MAC) but must be processed no later than 60 days after the close of

the performance period. The 2019 Claims Data Submission Fact Sheet can be found at

https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/444/2019%20Claims%20Data%20Submission%20Fact%20S

heet.pdf.

28. Many of the new eligible clinician types do not have an EHR and submit quality data by claims.

What do they do if their group is greater than 15 clinicians?

For the 2019 performance year, quality measures can be submitted using Medicare Part B claims

measures for clinicians in a small practice, either at the group or individual level. Practices with

greater than 15 providers will not be able to submit via claims. They will need to choose another

submission type including qualified registry, qualified clinical data registry, direct, log in and

upload, log in and attest, or the CMS Web Interface. Note that not all measures are eligible for

all submission methods. Be sure to confirm that the measures you would like to submit data for

available for your selected submission method by checking the measure specifications available

in the QPP Resource Library at https://qpp.cms.gov/about/resource-library.

29. As a pro fee only small (8 radiologists) radiology group with no control of EHRs, 4 different

facilities, basically no international and little patient contact, currently submitting on claims

successfully, do you see that option for submitting via claims continuing, and do you have any

suggestions for meeting criteria in other areas? (We are worried about the day that claims

submission is phased out.)

In 2019, CMS continues to allow Medicare Part B claims submissions for the quality category for

both individual clinicians and small groups of 15 or less clinicians. CMS evaluates each Quality

Payment Program performance year independently, so it has not yet been determined if claims

will continue to be a reporting option in future years. For advice on meeting reporting

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requirements, please reach out to your local Technical Assistance Contractor. You can locate

your Technical Assistance Contractor at https://qpp.cms.gov/about/help-and-support.

30. I do not understand the g codes. How do we put them into our notes?

Follow these steps to submit your 2019 Medicare Part B claims data for the MIPS Quality

performance category:

1. Append QDC(s): Submit your quality data for MIPS through your Medicare Part B claims

by appending a QDC to your claims form with dates of service during the performance

period– January 1, 2019 through December 31, 2019.

2. Insert a Charge: When you attach a QDC to your claim, you must include $0.00 line-item

charge for the QDC. If your billing software will not accept a code without a charge,

attach a $0.01 line-item charge for the QDC. An entry in the line-item charge box on the

claim form is a requirement for quality reporting via claims to CMS.

3. Check for Accuracy: CMS encourages clinicians and their staff to review the claims for

accuracy prior to submission for reimbursement and reporting purposes.

4. Medicare Administrative Contractor (MAC) Processing: Claims are processed by the MACs

(including claims adjustments, re-openings, or appeals) and must get to the national

Medicare claims system data warehouse (National Claims History file) no later than 60

days following the close of the performance period to be analyzed.

Don’t wait! For patient encounters that occur towards the end of the performance year

(December 31, 2019), be sure to file claims quickly. Medicare Part B claims (with the appropriate

QDCs) must be processed no later than 60 days after the close of the performance period to be

counted for quality reporting. Please work with your MAC for specific instructions on how to bill.

For more information on claims submission, please see the 2019 Claims Data Submission Fact

Sheet. Please reach out to your region’s Technical Assistance Contractor for additional support

regarding proper submission of claims data. Information for your region’s Technical Assistance

Contractor can be found at https://qpp.cms.gov/about/small-underserved-rural-practices.

31. My hospital's IT department turned off all "PQRS" or quality codes from auto-populating on

claims. Do I need to be concerned about my provider's quality score? He is independent and not

part of the hospital's ACO, so we attest for him as he is not included in any group reporting.

If the provider is MIPS eligible and intends to report quality measures via claims, then it is

important that the appropriate Quality Data Codes (QDCs) are attached to the provider’s

Medicare Part B claims. Claims received without the appropriate QDCs will not count towards

their MIPS performance. Be sure to implement a workflow or process to ensure the necessary

QDCs are added to the claims submissions, if you choose to submit via claims.

Be sure to also check the Participation Lookup tool to confirm whether the provider is eligible for

the MIPS program and if they are included under the group TIN. The tool is available at

https://qpp.cms.gov/participation-lookup. The Lookup tool will also note whether this provider is

categorized as a facility-based clinician. If the provider is determined to be facility-based, CMS

will automatically apply facility-based measurement to his/her Quality and Cost performance

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category scores. For more information on facility-based measurement, please see the 2019

Merit-Based Incentive Payment Program (MIPS) Facility-Based Measurement Fact Sheet at

https://qpp-cm-prod-content.s3.amazonaws.com/uploads/454/2019%20Facility-

Based%20Measurement%20Fact%20Sheet_Final.pdf.

32. We need help with coding MIPS measures on our claims so that our EMR can catch what we do.

Figuring out what G codes, Category II codes, and Dx CPT10 codes to use for a visit has become a

jungle. We are Family Practice and we do a lot of minor surgeries.

Each quality measure you select to report via claims has more than one Quality Data Code

(QDC). QDCs consist of a combination of Healthcare Common Procedure Coding System (HCPCS)

G-codes and Current Procedural Terminology (CPT) Category II codes. You will need to append

the appropriate QDCs to your claim form. For each claim measure, there are different QDCs that

tell CMS whether the patient encounter is included in the Numerator, and why. QDCs must be

reported by the same clinician who performed the covered service by applying the appropriate

encounter codes, such as ICD-10-CM, CPT Category I, or HCPCS codes. The codes are used to

identify the measure’s denominator. For Quality measure codes and details, please see the 2019

Medicare Part B Claims Measure Specifications and Supporting Documents. For more

information on claims, please visit the 2019 Claims Data Submission Fact Sheet at https://qpp-

cm-prod-

content.s3.amazonaws.com/uploads/444/2019%20Claims%20Data%20Submission%20Fact%20S

heet.pdf. In addition, we recommend taking advantage of the free support available to you

through your local Technical Assistance Contractor. You can locate your Technical Assistance

Contractor at https://qpp.cms.gov/about/help-and-support.

Measures 33. Are any Quality Measures topped out for 2019? I know they might not be eligible for total

points, but how do I find out which, if any, are finished?

The Quality Measure Benchmarks include information on whether the benchmark is topped out,

meaning the measure is not showing much variability and may have different scoring in future

years. There are several Quality Measures that are topped out for 2019. You can find the topped

out measures in the 2019 MIPS Quality Historic Benchmarks file at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/342/2019%20MIPS%20Quality%20Benchmarks.zip.

34. We are a group of hospitalists with no outpatient care. Our quality measures are limited based

on the inpatient codes we bill, and we clearly cannot control our patient value. Therefore,

getting a minimum of 20 patients for certain measures is difficult. In addition, we do not have an

EHR to help these numbers.

There may still be some measures available that your group can report. Each individual measure

specification determines the eligible patient population applicable to that measure. You can find

measures using the Explore Measures Tool at https://qpp.cms.gov/mips/explore-

measures/quality-measures.

Another option may be facility-based measurement. The 2019 MIPS performance year is the first

year that CMS will apply facility-based measurement. CMS will automatically apply facility-based

measurement to the Quality and Cost performance category scores if MIPS eligible clinicians,

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groups, and virtual groups are determined to be facility-based. Therefore, you will not need to

submit any data for the Quality performance category to be considered for facility-based

measurement. For more information on facility-based measurement, please see the 2019 Merit-

Based Incentive Payment Program (MIPS) Facility-Based Measurement Fact Sheet at

https://qpp-cm-prod-content.s3.amazonaws.com/uploads/454/2019%20Facility-

Based%20Measurement%20Fact%20Sheet_Final.pdf.

Your local Technical Assistance Contractor can help you pick quality measures that are right for

your group. Information for your region’s Technical Assistance Contractor can be found at

https://qpp.cms.gov/about/small-underserved-rural-practices.

35. We are a General Surgery office and we need help with choices to submit.

You can find the General Surgery measures at https://qpp.cms.gov/mips/explore-

measures/quality-measures?py=2019&specialtyMeasureSet=General%20Surgery or by using the

Explore Measures Tool. You can also sort and search measures by specialty by visiting

https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip. Your

local Technical Assistance Contractor can also help you with identifying measures that best suit

your practice. Information for your region’s Technical Assistance Contractor can be found at

https://qpp.cms.gov/about/small-underserved-rural-practices.

36. What are the plastic surgery measures and improvement activities?

You can find Plastic Surgery measures at https://qpp.cms.gov/mips/explore-measures/quality-

measures?py=2019&specialtyMeasureSet=Plastic%20Surgery or by using the Explore Measures

Tool. You can also sort and search measures by specialty by visiting https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip. For a

complete list of the 2019 Improvement Activities, please visit https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/346/2019%20Improvement%20Activities.zip.

37. If there are not enough reportable measures due to your specialty and the CPT codes that you

report, what alternate do you have?

If you submit via claims or a qualified registry and submit fewer than six measures (or no

outcome or high priority measure), CMS will use what is called the Eligibility Measure

Applicability (EMA) process to determine if additional clinically related measures could have

been submitted. If CMS finds that there are no applicable measures for you, you won’t be held

accountable for not submitting those measures. If CMS discovers that additional clinically related

measures could have been submitted and were not, it will impact your Quality performance

category final score. For more information, see the EMA Fact Sheet here: https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/164/2018%20QPP%20EMA.zip

You may also be able to report more measures by working with a third-party intermediary, like a

Qualified Registry (QR) or a Qualified Clinical Data Registry (QCDR), to submit data for MIPS. A

QR is an entity that collects clinical data from an individual MIPS-eligible clinician, group, or

virtual group and submits it to CMS on their behalf. Clinicians work directly with their registry to

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submit data on the selected measures or specialty set of measures. A QCDR is a CMS-approved

entity that collects clinical data on behalf of clinicians for data submission. Unlike QRs, QCDRs

are not limited to measures within the Quality Payment Program. Your local Technical Assistance

Contractor can also assist you with finding additional measures to report. You can locate your

region’s Technical Assistance Contractor at https://qpp.cms.gov/about/small-underserved-rural-

practices.

38. Should you consider reporting measures that are outside your scope of practice to meet

reporting requirements?

You are not restricted to only submitting your specialty’s measures. You may submit other

measures if you meet the criteria in the measure specification. You can find measures using the

Explore Measures Tool at https://qpp.cms.gov/mips/explore-measures/quality-measures. You

can also sort and search measures by specialty by visiting https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip.

39. Is it necessary to have six quality measures for 2019?

To meet the Quality performance category requirements, a clinician, group, or virtual group

must submit six quality measures for the 12-month performance period. The six quality measures

must include at least one outcome measure or another high-priority measure. If you choose to

submit measures from a specialty measure set and the measure set has fewer than six measures,

then you must submit all measures within the specialty set. Please note that the total available

measure achievement points is the number of required measures times 10, therefore if a

specialty set only contains five measures, the total available points will be 50 rather than 60. If

you are a group or virtual group with 25 or more clinicians, you also have the option to submit all

the quality measures included in the CMS Web Interface.

40. Is there anything new to report on for dermatology?

To find dermatology measures, please visit https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip. You can

sort and search measures by specialty using the 2019 Clinical Quality Measure Specifications and

Supporting Documents.

Promoting Interoperability 41. For 2018, does a MIPS clinician who works in both a hospital and a practice need to include

emergency department data on their Promoting Interoperability measures?

Hospital-based MIPS eligible clinicians qualify for automatic reweighting of the Promoting

Interoperability category and are not required to submit data for the PI category. However, to

qualify as a hospital-based MIPS eligible clinician:

• If you report for MIPS as an individual clinician, you have to furnish 75% or more of your

covered professional services in the inpatient hospital, on-campus outpatient hospital,

off-campus outpatient hospital or emergency room settings (based on place of service

codes) during the applicable determination period.

• If you report for MIPS as part of a group or virtual group, all of the MIPS eligible

clinicians in the group must furnish 75% or more of their covered professional services in

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the inpatient hospital, on-campus outpatient hospital, or, off-campus outpatient hospital

emergency room settings (based on place of service codes) during the determination

period prior to the performance period as specified by CMS.

If reporting for MIPS as a group, all MIPS eligible clinicians in the group must qualify for

reweighting in order for the performance category score to be reweighted. You can also be

exempt from submitting data to the Promoting Interoperability category if you applied for and

received a Promoting Interoperability hardship exception.

More information on 2018 Promoting Interoperability measures can be found in the 2018

Promoting Interoperability Measure Specifications.

42. Our problem is with interoperability. Our EHR can send information to other providers, but none

of the doctors we refer to are able to accept the information our system sends. How is this going

to affect our score? We do send information to our state's Medicaid registry.

One Technical Assistance Contractor offered the advice that you could call your most frequently

referred to practices or facilities and see if they would work with you on the bilateral exchange of

information because they may have the same measures they are trying to meet. You could also

become part of your state’s Health Information Exchange (HIE).

The Health Information Exchange objective is that the MIPS eligible clinician provides a summary

of care record when transitioning or referring their patient to another setting of care, receives or

retrieves a summary of care record upon the receipt of a transition or referral or upon the first

patient encounter with a new patient, and incorporates the summary of care information from

other health care providers into their EHR using CEHRT. In 2019, there are two Health

Information Exchange measures: Support Electronic Referral Loops by Sending Health Care

Information (formerly Send a Summary of Care) and Support Electronic Referral Loops by

Receiving and Incorporating Health Information (new). The two measures will earn you a

maximum score of 20 points each. The Send a Summary of Care measure was renamed to

Support Electronic Referral Loops by Sending Health Information. CMS also removed the Clinical

Information Reconciliation measure and combined it with the Request/Accept Summary of Care

measure to create a new measure, Support Electronic Referral Loops by Receiving and

Incorporating Health Information. The new measure includes actions from both the

Request/Accept Summary of Care measure and Clinical Information Reconciliation measure.

There is also the HIE measure’s exclusion which can be claimed by any MIPS eligible clinician who

transfers a patient to another setting or refers a patient fewer than 100 times during the

performance period. You can reach out to your region’s Technical Assistance Contractor for

additional free support. You can locate your local Technical Assistance Contractor at

https://qpp.cms.gov/about/small-underserved-rural-practices.

43. I've been following Medicaid Promoting Interoperability very closely but have lost track of MIPS

Promoting Interoperability. Can anyone cover the differences in measures between those two

Promoting Interoperability programs? Do the four MIPS Promoting Interoperability objectives

align with any Medicaid Promoting Interoperability measures?

20

For more information on the requirements of the Medicaid Promoting Interoperability (PI)

Program, please visit https://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/2019ProgramRequirementsMedicaid.html. There,

you will find helpful resources, including the 2019 Medicaid Hospital Specifications Sheets and

the 2019 Medicaid Eligible Professional Specification Sheets. More information on the MIPS

Promoting Interoperability category can be found in the 2019 Promoting Interoperability

Category Fact Sheet at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/487/2019%20MIPS%20Promoting%20Interoperability%20F

act%20Sheet.pdf. Your local Technical Assistance Contractor can also assist you with

understanding the differences between PI for Medicaid versus PI for MIPS. You can locate your

region’s Technical Assistance Contractor at https://qpp.cms.gov/about/small-underserved-rural-

practices.

44. How do we know when an EMR vendor “sells” an added program to be able to improve scores

(e.g. direct messaging, PDMP)?

Please reach out to your EHR vendor to find out what programs and services they provide. Every

EHR vendor has different reporting capabilities. You will need to discuss with your EHR vendor

the specifics of what they will submit on your behalf. In addition, check to make sure your EHR

vendor provides the support you need to keep up-to-date on the EHR certification requirements.

For the 2018 performance year, the Promoting Interoperability (PI) category requires 2014 or

2015 edition Certified Electronic Health Record Technology (CERHT). In 2019, the PI category

requires 2015 edition CEHRT for the full year.

45. How do we attest if our EMR vendor is not calculating the numbers correctly?

Please reach out to your EHR vendor to ensure your data is being calculated correctly. You can

also quality check your EHR vendor’s calculations by referring to the measure specifications for

the measure you plan to submit. The measure specifications for 2019 can be found at

https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip. You

may also consult the QPP Helpdesk because there could be a reason for you to be granted a

hardship exemption. you can contact the QPP helpdesk at 1-866-288-8292. Another option is to

request a targeted review, in which case CMS would review the calculation of your payment

adjustment. Please see the MIPS Targeted Review Fact Sheet for more information.

An alternative to submitting via an EHR, is submitting via a third-party intermediary, like a

Qualified Registry (QR) or a Qualified Clinical Data Registry (QCDR). A QR is an entity that collects

clinical data from an individual MIPS-eligible clinician, group, or virtual group and submits it to

CMS on their behalf. Clinicians work directly with their registry to submit data on the selected

measures or specialty set of measures. A QCDR is a CMS-approved entity that collects clinical

data on behalf of clinicians for data submission. Unlike QRs, QCDRs are not limited to measures

within the Quality Payment Program.

Clinician or groups may also submit a Promoting Interoperability Hardship Exception Application,

citing one of the following reasons for review and approval:

21

• MIPS eligible clinician in a small practice

• MIPS eligible clinician using decertified EHR technology

• Insufficient Internet connectivity

• Extreme and uncontrollable circumstances

• Lack of control over the availability of CEHRT

If you receive an exception for the PI category, the PI category would receive a 0 weight in

calculating your final score, and the 25% is reallocated to the Quality category, making the

Quality category worth 70 points. More detailed information on PI can be found on the QPP

website at https://qpp.cms.gov/mips/promoting-interoperability?py=2019.

Please contact your local Technical Assistance Contractor for help reporting for the Promoting

Interoperability category. Information for your region’s Technical Assistance Contractor can be

found at https://qpp.cms.gov/about/small-underserved-rural-practices.

46. As an orthopedic surgery practice we are often the last step in a patient's musculoskeletal care,

meaning we do no often refer patient's out to other providers. This being said, we are a sub-

specialty practice and providers will refer to another specialist in-office for a different extremity.

Regarding Closing the Referral Loop and Sending/Receiving a Summary of Care – does this count

to refer to another specialist in the same practice, being the patient will be treated for a

completely different injury (For example, foot ankle specialist refers patient to our shoulder

specialist)?

Yes, referring a patient to another specialist in the same practice would count for the Support

Electronic Referral Loops by Sending Health Information. For the Support Electronic Referral

Loops by Receiving and Incorporating Health Information, this would count if the MIPS eligible

clinician has never before encountered the patient. According to the 2019 Promoting

Interoperability Measure Specifications, the Support Electronic Referral Loops by Sending Health

Information measure is met if for at least one transition of care or referral, the MIPS eligible

clinician that transitions or refers their patient to another setting of care OR health care

provider creates a summary of care record using certified electronic health record technology

(CEHRT) and electronically exchanges the summary of care record. The Support Electronic

Referral Loops by Receiving and Incorporating Health Information is met if for at least one

electronic summary of care record received for patient encounters during the performance

period for which a MIPS eligible clinician was the receiving party of a transition of care or

referral, or for patient encounters during the performance period in which the MIPS eligible

clinician has never before encountered the patient, the MIPS eligible clinician conducts clinical

information reconciliation for medication, medication allergy, and current problem list.

Please note that the Support Electronic Referral Loops by Sending Health Information measure’s

exclusion can be claimed by any MIPS eligible clinician who transfers a patient to another setting

or refers a patient fewer than 100 times during the performance period. There are two exclusions

for the Support Electronic Referral Loops by Receiving and Incorporating Health Information: (1)

any MIPS eligible clinician who is unable to implement the measure for a MIPS performance

period in 2019 and (2) any MIPS eligible clinician who receives fewer than 100 transitions of care

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or referrals or has fewer than 100 encounters with patients never before encountered during the

performance period.

47. Do you have any tips on how to obtain contact information from referring providers in order to

Send/Accept Summary of Care documents (Promoting Interoperability)?

One Technical Assistance Contractor offered the advice that you could call your most frequently

referred to practices or facilities and see if they would work with you on the bilateral exchange of

information because they may have the same measures they are trying to meet. You could also

become part of your state’s Health Information Exchange (HIE).

48. What are the exclusions for Promoting Interoperability objectives/measures?

In 2019, if you are one are one of these types of MIPS eligible clinicians, you qualify for automatic

reweighting of the PI category:

• Ambulatory Surgical Center (ASC)-based MIPS eligible clinicians

• Hospital-based MIPS eligible clinicians

• Non-patient facing clinicians

• Physician assistants

• Nurse practitioners

• Clinical nurse specialists

• Certified registered nurse anesthetists

• Physical therapists

• Occupational therapists

• Qualified speech-language pathologists

• Qualified audiologists

• Clinical psychologists

• Registered dietitian or nutrition professionals

Your Promoting Interoperability category may also be reweighted if you’re a MIPS eligible

clinician or group who applied for and received a Promoting Interoperability hardship exception

based on one of these reasons:

• You have insufficient internet connectivity

• You have extreme and uncontrollable circumstances, including disaster, practice closure,

severe financial distress (bankruptcy or debt restructuring), or vendor issues

• You don’t have control over whether CEHRT is available

• You’re using decertified EHR technology

• You’re in a small practice

If you qualify, you may also claim exclusions for the Promoting Interoperability measures. You

can find a detailed overview of the requirements for the 2019 Promoting Interoperability

category objectives and measures in the 2019 Promoting Interoperability Measure

Specifications.

49. What is the difference between Promoting Interoperability for Meaningful Use and for MIPS?

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The Promoting Interoperability (PI) performance category under MIPS and the Medicare

Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals are both

similar in their efforts to improve interoperability and patients’ access to health information. The

PI performance category under MIPS replaced the Medicare EHR Incentive Program for Eligible

Professionals (aka Meaningful Use). More information regarding the specific measures and

requirements for the PI performance category can be found at

https://qpp.cms.gov/mips/promoting-interoperability.

50. Can you explain the difference between Syndromic Surveillance reporting and Public Health

Reporting? Can you provide examples of what should be submitted to each (TB, HIV, Meningitis,

Anthrax, Measles, etc.)?

Syndromic Surveillance Reporting and Public Health Registry Reporting are both measures under

the Public Health and Clinical Data Exchange objective for the Promoting Interoperability

category. The Syndromic Surveillance Reporting measure is met if the MIPS eligible clinician is in

active engagement with a public health agency to submit syndromic surveillance data from a

non-urgent care setting. The Public Health Registry Reporting measure is met if the MIPS eligible

clinician is in active engagement with a public health agency to submit data to public health

registries. For more detailed information on these two measures, please see the 2019 Promoting

Interoperability Measure Specifications at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/343/2019%20Promoting%20Interoperability%20Measure%

20Specifications.zip.

Accountable Care Organizations (ACOs) 51. We are in an ACO (MSSP1). For Promoting Interoperability, what providers do we need to

submit (e.g. hospital-based, exempt from MACRA (less than $90K, < 200 patients, etc.), new

providers (PT, OT, Dieticians, etc.))?

Accountable Care Organization (ACO) participants are scored at the group or solo practice (TIN)

level for eligible clinicians subject to the Promoting Interoperability (PI) category. You would not

need to submit data for the Promoting Interoperability Category if you are one of the newly

eligible MIPS specialties (e.g. physical therapists, occupational therapists, qualified speech-

language pathologists, qualified audiologists, clinical psychologists, and registered dietitian or

nutrition professionals) or any of these other MIPS specialty types:

• Ambulatory Surgical Center (ASC)-based MIPS eligible clinicians

• Hospital-based MIPS eligible clinicians

• Non-patient facing clinicians

• Physician assistants

• Nurse practitioners

• Clinical nurse specialists

• Certified registered nurse anesthetists

You can also be exempt from submitting data to the Promoting Interoperability category if you

applied for and received a Promoting Interoperability hardship exception. If you receive an

exception for the PI category, the PI category would receive a 0 weight in calculating your final

score, and the 25% is reallocated to the Quality category, making the Quality category worth 70

points.

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In addition, MIPS eligible clinicians who are identified in one of the first three performance year

snapshots (March 31, June 30, and August 31) during the 2019 QP performance period may

become Qualifying APM Participants (QPs) for the performance year. If these eligible clinicians

meet thresholds to become QPs for the year, they will receive an APM incentive payment and be

excluded from MIPS reporting and therefore do not have to report PI Objectives and Measures in

2019. For those Next Generation ACO participants that do not qualify as a QP, they fall under the

MIPS APM scoring standard and should have PI data submitted.

More detailed information on PI can be found in the 2019 Promoting Interoperability Category

Fact Sheet at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/487/2019%20MIPS%20Promoting%20Interoperability%20F

act%20Sheet.pdf.

52. None of the rehabilitation software (national software vendors) have their software certified

(because they don't do eRx, drug-drug, drug-allergy, etc.). What are Physical

Therapists/Occupational Therapists doing? They have no software that is nationally available

that works for them. They are part of an ACO (MSSP).

Accountable Care Organizations (ACOs) participants are scored at the group or solo practice

(TIN) level for eligible clinicians subject to the Promoting Interoperability (PI) category. Physical

therapists and occupational therapists would not need to submit data for the Promoting

Interoperability Category because they are newly eligible MIPS specialties (e.g. physical

therapists, occupational therapists, qualified speech-language pathologists, qualified

audiologists, clinical psychologists, and registered dietitian or nutrition professionals). More

detailed information on PI can be found in the 2019 Promoting Interoperability Category Fact

Sheet at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/487/2019%20MIPS%20Promoting%20Interoperability%20F

act%20Sheet.pdf.

53. Should I reach out to my Technical Assistance Contractor for further information (MI-based

CAH/RHC)? I am seeking some general information on how being part of an ACO impacts our

MIPS participation.

We recommend leveraging the free support available to you through your local Technical

Assistance Contractor and reaching out to them for any questions you have about how ACO

participation impacts your practice.

In general, participating in an Accountable Care Organizations (ACOs) may either modify your

MIPS reporting requirements to follow the MIPS APM requirements or exclude you from MIPS if

the eligible clinicians qualify as a Qualifying APM Participant (QP). For more information on

Alternative Payment Models (APMs), please visit https://qpp.cms.gov/apms/overview.

Scoring and Payment Adjustments 54. We received a positive payment adjustment this year. Where can I find a list of CPT/HCPCS

codes it will apply to?

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The payment adjustments are applied to your Part B claims for services appearing on the

Medicare Physician Fee Schedule two years following the performance year. For example, for the

2017 QPP performance period, you will be seeing the associated payment adjustment applied to

your 2019 Part B claims. You should see the positive payment adjustment on your current Part B

claims Remittance Advice from Medicare. The Remittance Advice includes medical code sets such

as Healthcare Common Procedure Coding System (HCPCS) Level I and Level II Codes;

International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM); Current

Dental Terminology (CDT) Codes; and national Drug Codes (NDCs). Medicare Risk Adjustment

Eligible CPT/HCPCS Codes can be found at https://www.cms.gov/Medicare/Health-

Plans/MedicareAdvtgSpecRateStats/Risk-Adjustors-Items/CPT-HCPCS.html. Your Medicare Part B

Explanation of Benefits will also include a corresponding code indicating the adjustment is

specific to the 2017 year. For more information on scoring in performance year 2018, please see

the 2018 MIPS Scoring 101 Guide at https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/179/2018%20MIPS%20Scoring%20Guide_Final.pdf.

55. Will real-time tracking tools be available to verify progress in meeting MIPS requirements during

2019 and 2020?

If you have submitted claims for the Quality performance category, the portal will inform you of

the projected Quality performance score without having to upload additional data for the

category. Also, Qualified Registries (QRs) and Qualified Clinical Data Registries (QCDRs) are

required to provide participants with reports at least quarterly.

In addition, there are several MIPS calculators that allow you to enter your data and calculate an

estimated score. Some EHR vendors also have this information in the form of a dashboard. We

encourage you to reach out to your EHR vendor, as well as your region’s Technical Assistance

Contractor to see if they have recommended calculators. You can locate your local Technical

Assistance Contractor at https://qpp.cms.gov/about/small-underserved-rural-practices.

56. As an ENT specialist, what should I do to avoid a penalty?

The minimum score for performance year 2019 to avoid a downward payment adjustment is 30

points. You can meet the minimum threshold by collecting and submitting data in the Quality,

Improvement Activities, and Promoting Interoperability performance categories. Small practices

should keep in mind that they do not have to meet the data completeness criteria—they can still

earn 3 points per quality measure for submitting data even if they do not report data on 60% of

their patient population. Also, MIPS eligible clinicians in small practices who submit data on at

least one quality measure with receive 6 bonus points for the Quality performance category.

You can find measures to report on using the Explore Measures Tool at

https://qpp.cms.gov/mips/explore-measures/quality-measures. You can also sort and search

measures by specialty by visiting https://qpp-cm-prod-

content.s3.amazonaws.com/uploads/339/2019+CQM+Specs+and+Supporting+Docs.zip.

Using an ENT registry to report is also an option to consider because they would have applicable

measures for your specialty. The 2019 Qualified Registries Qualified Posting and the 2019

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Qualified Clinical Data Registries (QCDRs) Qualified Posting will provide lists of the 2019 CMS-

approved registries for the MIPS Program.

57. If a small practice is eligible to opt in for 2019, how many points are needed to achieve a neutral

adjustment?

In order to achieve a neutral adjustment, the clinician must achieve a minimum MIPS final score

of 30 points. As a reminder, beginning with the 2019 MIPS performance period/2021 MIPS

payment year, if an individual eligible clinician, group or APM Entity exceeds at least one but not

all three of the low-volume threshold criteria and elects to report on applicable measures and

activities under MIPS by electing to opt-in, then the individual MIPS eligible clinician, group, or

APM Entity will be considered MIPS eligible clinicians and will be assessed in the same way as all

other MIPS eligible clinician(s) for the applicable payment year. Clinicians and groups that elect

to opt-in will receive a MIPS payment adjustment based on their 2019 performance. Please note

that electing to opt-in will also expose your practice to potentially receiving a negative payment

adjustment if the MIPS final score is less than 30 points.

58. When will our 2018 Cost Scores be available to review?

Feedback on 2018 MIPS performance period cost measure performance will be available in the

summer of 2019.

59. How do I find our results from 2017?

Final scores and payment adjustments from the 2017 performance period are available on the

QPP Portal. If you submitted for the MIPS program in 2017 via claims, you should see your

corresponding payment adjustment on your 2019 Medicare Part B claims. Your Medicare Part B

Explanation of Benefits will also include a corresponding code indicating the adjustment is

specific to the 2017 performance year. We also encourage you to check your 2019 Part B

transmittals for any positive or negative adjustments at the claims level. For more information

about 2019 payment adjustments, please see the 2019 MIPS Payment Adjustment Fact Sheet.