Vol. 3 Ed.10 | September 24, 2020 |
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2020 Qualified Participant Notice for Alternative Payment Method (APM) Incentive Payment
The Centers for Medicare & Medicaid Services (CMS) has updated the Quality Payment Program (QPP) website to include 2020 APM Incentive Payment details. To access this information, clinicians and surrogates can now log in to the QPP website using their HARP credentials.
Eligible clinicians who were Qualifying APM Participants (QPs) based on their 2018 performance will begin receiving their 2020 5% APM Incentive Payments this month. CMS also posted a new 2020 APM Incentive Payment Fact Sheet to explain:
- Who is eligible to receive an APM incentive payment in 2020
- How CMS determines your 2020 APM Incentive Payment
- Frequently asked questions and answers
APM Incentive Payment Details Available on QPP Website
CMS has taken time to ensure correct payments and information are available during the 2020 payment year. CMS’s process includes verifying eligible clinicians’ Advanced APM participation and the calculation of the APM Incentive Payment.
You can now log in to the QPP website to see the amount and the organization paid for both the 10-digit National Provider Identifier (NPI) and the organization.
What Do I Need to Do in Order to Receive the APM Incentive Payment?
You will not need to do anything unless you have not yet received your payment and find your name on this public notice, which indicates that you will need to verify your Medicare billing information. If you do not verify your Medicare billing information by November 13, 2020, then CMS will not be able to issue your APM Incentive Payment. For instructions on how to verify your Medicare billing information, review the public notice.
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11 Days Remaining to Submit MIPS Targeted
Review Requests
If you participated in the Merit-based Incentive Payment System (MIPS) in 2019, your performance feedback, including your MIPS final score and payment adjustment factor(s), is now available for review on the QPP website. This final score determines the payment adjustment you will receive in 2021, with a positive, negative, or neutral payment adjustment being applied to the Medicare paid amount for covered professional services furnished by a MIPS eligible clinician in 2021.
MIPS-eligible clinicians, groups, and virtual groups (along with their designated support staff or authorized third-party intermediary), including Alternative Payment Model (APM) participants, may request the CMS to review the calculation of their 2020 MIPS payment adjustment factor(s) through a process called targeted review.
When to Request a Targeted Review
If you believe an error has been made in your MIPS payment adjustment factor(s) calculation, you can request a targeted review until October 5, 2020 at 8:00 p.m. (EDT). Some examples of previous targeted review circumstances include the following:
- Errors or data quality issues for the measures and activities you submitted.
- Eligibility and special status issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment).
- Being erroneously excluded from the APM participation list and not being scored under the APM Scoring Standard.
- Performance categories were not automatically reweighted even though you qualify for automatic reweighting due to extreme and uncontrollable circumstances.
Note: This is not a comprehensive list of circumstances. CMS encourages you to submit a request form if you believe a targeted review of your MIPS payment adjustment factor (or additional MIPS payment adjustment factor, if applicable) is warranted.
How to Request a Targeted Review
You can access your MIPS final score and performance feedback and request a targeted review by:
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Going to the QPP website.
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Logging in using your HCQIS Access Roles and Profile System (HARP) credentials; these are the same credentials that allowed you to submit your MIPS data. Please refer to the QPP Access Guide for additional details.
HCQIS = Health Care Quality Information Systems
CMS may require documentation to support a targeted review request that is under its evaluation. If the targeted review request is approved, CMS may update your final score and/or associated payment adjustment (if applicable), as soon as technically feasible. Please note that targeted review decisions are final and not eligible for further review.
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Submit Comments on the 2021 Proposed Rule for the QPP by October 5
Provide Feedback on Proposed Changes to the QPP by October 5, 2020
On August 3, CMS released its proposed policies for the 2021 performance year of the QPP via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM). CMS is seeking comment on a variety of proposals in the NPRM. Comments are due no later than 5 p.m. EDT, on Monday, October 5.
You must officially submit your comments in one of the following ways:
- Electronically, through Regulations.gov
- Regular mail
- Express or overnight mail
Key proposals for the QPP include:
- Increasing the complex patient bonus to a 10-point maximum for the 2020 performance year due to COVID-19.
- Postponing the implementation of the MIPS Value Pathways (MVPs) until 2022 instead of 2021.
- Introducing the APM Performance Pathway (APP) for participants in MIPS APMs beginning in 2021.
- Increasing the performance threshold to 50 points for the 2021 performance year (10 points less than the 60-point threshold finalized for 2021 in the CY 2020 PFS Rule).
- Decreasing the performance category weight for Quality to 40% and increasing Cost to 20%.
- Removing the CMS Web Interface as collection and submission types for reporting MIPS quality measures beginning with the 2021 performance period.
- Sunsetting the APM Scoring Standard and allowing MIPS-eligible clinicians to participate in MIPS under an APM Entity beginning in 2021.
For More Information
To learn more about the PFS NPRM and the QPP proposals, review the following resources:
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Fact Sheet―Offers an overview of the QPP proposed policies for 2021 and compares these policies to the current 2020 requirements.
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Webinar Recording―Details the QPP proposed policies for 2021, answers questions from webinar attendees, and shares information on how to comment.
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QPP COVID-19 Response Webpage―Shares information on the proposed complex patient bonus change and other flexibilities implemented in response to the public health emergency.
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Updates to the Security Risk Assessment (SRA) Tool
The Office of the National Coordinator (ONC), in partnership with the Office for Civil Rights (OCR) released an update to the Health and Human Services (HHS) Security Risk Assessment (SRA) Tool. This tool provides support for small- and medium-sized healthcare organizations in their efforts to assess security risks. The newly enhanced version of the SRA Tool includes a variety of new features, like improved navigation throughout the assessment sections, export options for reports, and enhanced user interface scaling.
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Frequently Asked Questions of the Month |
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Question: Why do I keep getting phone calls, faxes, or emails from HSAG?
Answer: This is HSAG's annual check-in regarding QPP MIPS reporting. Since 2017, HSAG has been mandated by CMS to confirm participation intent for all small practice MIPS-eligible clinicians on an annual basis.
Question: When will 2020 MIPS Final Eligibility Determination be released?
Answer: The MIPS Performance Year (PY) 2020 eligibility is anticipated to be finalized in December 2020.
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New QPP Tools and Resources |
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To prepare for the 2020 performance year of the MIPS, CMS has posted new resources to the QPP Resource Library.
QPP Resources:
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CMS COVID-19 Stakeholder Calls
CMS has been hosting regular calls with a variety of clinicians, hospitals, other facilities, and states in an effort to keep stakeholders updated on their COVID-19 efforts. CMS understands that not everyone is available to attend the calls live, and is sharing access to recordings along with transcripts. CMS will continue to host calls and share information through their list serves and media.
CMS COVID-19 Office Hour Calls (Tuesdays at 5–6 p.m. ET)
Office Hour Calls provide an opportunity for hospitals, health systems, and providers to ask questions of agency officials regarding CMS' temporary actions that empower local hospitals and healthcare systems to:
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Increase Hospital Capacity—CMS Hospitals Without Walls;
- Rapidly Expand the Healthcare Workforce;
- Put Patients Over Paperwork; and
- Further Promote Telehealth in Medicare
To keep up with the important work of the White House Coronavirus Task Force in response to COVID-19, visit https:/www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.
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COVID-19 Resources and Preparedness
In light of the COVID-19 pandemic, HSAG understands the priority to keep your patients and staff safe.
COVID-19 Resources:
CDC = Centers for Disease Control and Prevention
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HSAG Year 4 MIPS Participation Check-In
Each year, Health Services Advisory Group (HSAG) checks in with every eligible clinician and practice to ensure your plans for MIPS reporting are on track. You may receive phone calls, emails, and or fax communication from it throughout the year. Its goal is to ensure you are prepared to submit your best MIPS score, so it appreciates your time speaking with it and looks forward to hearing your MIPS reporting plans this year. If your practice knows your MIPS reporting plans for 2020 now, click here to let HSAG know. By submitting your MIPS participation plans online, HSAG will not reach out via phone, and you can contact HSAG when you need it!
HSAG is 1 of 11 organizations awarded by CMS as a QPP Technical Assistance Support Contractor. Since 2017, HSAG has been your trusted resource, available to Medicare providers in Arizona, California, Hawaii, New Mexico, and the U.S. Virgin Islands. Also, in partnership with Alliant Quality, HSAG is Florida’s technical assistance contractor for the QPP. HSAG provides assistance on MIPS and Alternative Payment Models (APMs); two reporting paths under the QPP. Its services are provided at no cost to you.
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Last Day to Start a 90-day Performance Period for Promoting Interoperability and Improvement Activities (October 3)
Targeted Review Period Closes October 5, 2020
Submit Comments on the 2021 Proposed Rule for the QPP by October 5
View the following resources to assist in planning for 2020 MIPS reporting:
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October National Health Observances
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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 here.
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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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