Volume 2 Ed. 12 | December 26, 2019
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Action Required: Check Final 2019 MIPS-Eligibility Status
- Your initial 2019 Merit-based Incentive Payment System (MIPS)-eligibility status was based on the Centers for Medicare & Medicaid Services (CMS) review of Medicare Part B claims and Provider Enrollment, Chain and Ownership System (PECOS) data from October 1, 2017, to September 30, 2018.
- Now, CMS has updated your eligibility status based on its second review of Medicare Part B claims and PECOS data, from October 1, 2018, to September 30, 2019.
Check Your Final 2019 MIPS-Eligibility Status
- Eligible for MIPS: Your eligibility status might change, and you may no longer be eligible. You should use the tool to make sure you are still eligible.
- Not eligible for MIPS at a particular practice: Your eligibility status, based on your association with that particular practice, will not change.
For More Information
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Third MIPS Low-Volume Threshold Criteria for 2019
CMS has added a third low-volume threshold criterion for determining MIPS eligibility for 2019. Clinicians and groups are excluded from MIPS if they:
- Billed $90,000 or less in Medicare Part B allowed charges for covered professional services during either of the two determination periods (October 1, 2017–September 30, 2018 or October 1, 2018–September 30, 2019); OR
- Provided care to 200 or fewer Part B-enrolled patients during either of the two determination periods; OR
- New for 2019—Provided 200 or fewer covered professional services under the Physician Fee Schedule during either of the two determination periods.
In order to be eligible for MIPS, a clinician or group must exceed all three criteria listed above. You can check the
QPP Participation Status Tool to view your final 2019 eligibility status for MIPS.
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Deadline Reminder: 2019 Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Exceptions Due December 31
Who Is Eligible for a Promoting Interoperability Hardship Exception?
MIPS-eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0 percent if they:
- Are a small practice;
- Have decertified EHR technology;
- Have insufficient Internet connectivity;
- Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
- Lack control over the availability of certified electronic health record technology (CEHRT)
Note: If you are already exempt from reporting Promoting Interoperability data, you do not need to apply.
Who Is Eligible for an Extreme and Uncontrollable Circumstances Exception?
MIPS-eligible clinicians, groups, and virtual groups may qualify for a re-weighting of any or all MIPS performance categories to 0 percent if they are affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must render them unable to:
- Collect information necessary to submit for a performance category; or
- Submit information that would be used to score a performance category for an extended period of time.
Note: Individual MIPS-eligible clinicians (not groups or virtual groups) will receive the exception automatically if they are located in a CMS-designated region that has been affected by an extreme and uncontrollable event during the 2019 MIPS Performance Year. These clinicians will not need to apply for the exception.
How Do I Know If I Am Approved?
If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the
QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2020.
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Deadline Reminder: Virtual Group Election Period
Ends December 31
If you are interested in forming a virtual group for the 2020 MIPS performance year, the election period started October 1, 2019, and you must submit your election to CMS
via email before
December 31, 2019.
What Is a Virtual Group?
A virtual group is a combination of two or more Taxpayer Identification Numbers (TINs) assigned to:
- One or more solo practitioners (who are MIPS-eligible clinicians); or
- One or more groups consisting of 10 or fewer clinicians (including at least one MIPS-eligible clinician); or
- Both (solo practitioners and groups of 10 or fewer clinicians) that elect to form a virtual group for a performance period for a year.
Note: A solo practitioner or group can only participate in one virtual group during the performance period.
What Is the Election Process?
There is a two-stage election process for forming a virtual group:
Stage 1 (optional)
- Contact your QPP Technical Assistance organization for information regarding Tax Identification Number (TIN) size to help you determine if you meet the TIN-size criteria to join or form a virtual group.
Stage 2 (required)
As part of Stage 2 of the election process, you must:
- Have a formal written agreement;
- Name an official virtual group representative;
- Submit the virtual group’s election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by December 31, 2019;
- Determine group size and low-volume threshold.
Download the
2020 Virtual Groups Toolkit (ZIP) to learn more about the election process and how to participate in MIPS as a virtual group in 2020.
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Participating Through the Opt-In or Voluntary-Reporting Options
Clinicians and groups who are not eligible for MIPS can still choose to report data to MIPS by:
- Making an Election to Opt-in or Voluntarily Report: Clinicians and groups who are identified as “opt-in eligible” on the QPP Participation Status Tool have exceeded one or two of the low-volume threshold criteria, and can make an election to:
- Opt-in to MIPS. You will receive a MIPS-payment adjustment (positive, negative or neutral)
- Voluntarily Report. You will not receive a MIPS-payment adjustment.
- Note: Once made, your election is binding and irreversible. (No election is required if you do not want to report data to MIPS.)
- Voluntarily Report (no election required): Clinicians and groups who are excluded from MIPS and are not “opt-in eligible” because they fall below all three of the low-volume threshold criteria may choose to voluntarily report data to MIPS and will not receive a MIPS-payment adjustment.
Next Steps
To review your eligibility status, enter your National Provider Identifier (NPI) on the
QPP Participation Status Tool or sign in to
qpp.cms.gov to review your eligibility as a group and individually for all the clinicians associated with your practice.
Before reporting data, opt-in eligible clinicians and groups will need to complete an election to opt-in or voluntarily report in MIPS by signing in to
qpp.cms.gov. Qualified Registries and Qualified Clinician Data Registries (QCDRs) can also submit elections on behalf of clinicians and groups. Elections can be made once the 2019 MIPS submission period opens on January 2, 2020.
For More Information
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The MIPS-submission window is quickly approaching. Have you established a Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account and identified roles needed for submission? Check out some HARP Frequently Asked Questions at the
CMS HARP Help website. If you have a HARP account, the following are some tips to keep your account active and how to create a strong password.
Passwords must:
- Be changed every 60 days.
- Be changed prior to expiration.
- Are changed by going to portal.cms.gov > My Profile>Click on Change My Profile>Change Password.
- Contain between eight and twenty characters.
- Contain at least one upper case letter, lower case letter, and number.
- Not contain a dictionary word of five letters or more.
- Not contain more than four sequential numbers, such as 1234.
- Contain a special character.
- Not contain these special characters: ? < > ( ) ' " ? | &.
Here are some examples of acceptable passwords:
- Hbfc#867 or H@ll0ween (CAP Initials of first and last name-@-lower case business initials and 3 numbers)
- JA@hc876 (Josh Allen who works at Health Clinic)
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New QPP Tools and Resources
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The following resources were either updated or created on the QPP Resource Library after the last QPP Quest was released.
2020
2019
2018
2017
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QPP Frequently Asked Question of the Month
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Question: W
here can I find an overview of the policies that were finalized for the 2020 performance period?
Answer:
CMS has provided an overview of the major policies that were finalized for performance period 2020 in the calendar year (CY)
2020 QPP Final Rule Fact Sheet
(PDF), which includes a table comparing the previous policy to the newly finalized policy. CMS also hosted a public webinar in mid-November that reviewed the major changes in the Final Rule and is available in the
QPP Webinar Library
on qpp.cms.gov.
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Upcoming Learning Forum Fridays (LFF) Events
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Did You Miss the December 13 LFF Webinar?
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Centers for Medicare & Medicaid Services Updates
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QPP—MIPS Question and Answer Town Hall Event for Solo and Small Group Practices
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Thursday, January 23, 2020
3:30 p.m.–4:30 p.m. ET
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Tuesday, January 28, 2020
11:00 a.m.–12 noon p.m. ET
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2019 MIPS Performance Period
Data Submission Window
2020 MIPS Performance Period
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Subscribe to Get the Information You Need
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Subscribe to HSAG's QPP Quest Digest
Invite your practice staff, practices you refer patients to, and other colleagues to subscribe to HSAG’s QPP Quest Digest!
Stay informed of all monthly QPP updates, deadlines, no-cost webinars and best practices by subscribing
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CMS QPP Listserv
Don't forget to sign up on the
CMS.gov QPP website
. Once you've accessed the QPP page, scroll to
[Subscribe to Updates]
at the bottom of the page and insert your email address before clicking
[Subscribe]
. The QPP listserv is a valuable resource to stay informed of webinars and important QPP deadlines.
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