MIPS 2019 Count-Down to the End of 2019 – September’s TO-DO List

September 16, 2019

Written by Sharon Phelps

There is just over three months left in 2019. It’s time to ensure you are on track to get the best Merit-based Incentive Payment System (MIPS) score you can for 2019. To help you out, here are a few items you should be doing from NOW to end the year to keep you in great shape for MIPS reporting.

1. Review your 2018 feedback report in the Medicare Quality Payment Program (QPP) portal if you have not already done so. The targeted review process is the mechanism to request Centers for Medicare & Medicaid Services (CMS) to review your 2018 feedback report and/or your 2020 payment adjustment. The deadline to file a targeted review is September 30. Once that window closes, you will not have another opportunity to report an error or issue with your 2018 data. To file a targeted review, go into your QPP portal. This action is located where you view your 2018 MIPS results. Look for the large blue button on the bottom of the page.

Here’s what you should be reviewing in your feedback report:

1. Sub-category scores – do they match what you reported and what you expected? If not, investigation is needed, and you may want to file a targeted review to have CMS take a closer look.
2. Cost category scores – review the overall results and download the detailed data. There is a growing body of information on this category in the resource library on the QPP website. For more information on this category, you can review webinars on the Cost Category on Mountain-Pacific Quality Health’s website.
3. Items and services – this section gives you information on the volume of services received by the Medicare beneficiaries to whom you have provided services.
4. Payment adjustment calculation – the payment adjustments remain relatively low this year due to the budget neutral design of the MIPS program. 98 percent of eligible clinicians successfully reported to MIPS this year, so the pool of money for positive adjustments in the budget neutral portion is quite low.

Here’s a few resources if you want to learn more:

1. Targeted Review User Guide
2. 2018 Performance Feedback FAQs
2. Request a hardship exemption, if applicable, for the Promoting Interoperability (PI) category. The window to request this exemption closes on December 31, 2019 but it is quick and simple to do so. This is a good item to cross off your to-do list now. The following are reasons for requesting an exemption:
1. MIPS-eligible clinician in a small practice (15 or fewer clinicians)
2. MIPS-eligible clinician using decertified electronic health record (EHR) technology
3. Insufficient internet connectivity
4. Extreme and uncontrollable circumstances
5. Lack of control over the availability of certified EHR technology (CEHRT)

See the PI hardship exemption application and more information.

3. Determine your 90-day period for the Improvement Activity and/or Promoting Interoperability categories you have selected. Both categories require only 90 days of activity. You still have time to get ready if you are going to start on October 3, 2019, the last day to start to meet the requirements.
1. Promoting Interoperability – ensure your electronic records meet the 2015 CEHRT standards to be able to report in this category in 2019.
2. Improvement activities – review your selected improvement activity in the 2019 MIPS Data Validation Criteria for recommendations on documentation for your audit folder. You can find the data validation criteria on our website.

If you have further questions, please feel free to contact our team of MIPS experts at qualitypaymenthelp@mpqhf.org. We are here to help you be successful with MIPS and enjoy answering your questions and supporting your MIPS activities.

Other Resource Links
CMS QPP Website
HTS MIPS Services
MIPS Eligibility – 4 Steps
See all Previous MIPS blogs

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