The QPP Quest
Volume 2 Ed. 10 | October 24, 2019
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Hot Off the Press!
Virtual Group Election Period Open Now!

If you are interested in forming a virtual group for the 2020 Merit-based Incentive Payment System (MIPS) performance year, the election period started October 1, 2019, and you must submit your election to the Centers for Medicare & Medicaid Services (CMS) via email before December 31, 2019.

What Is a Virtual Group?
A virtual group is a co mbination 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 1 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 an Election Process?
There is a two-stage election process for forming a virtual group:

Stage 1 (optional)

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.  
2019 MIPS Quality Measures Impacted by ICD-10 Updates Effective October 1, 2019

Which Quality Measures Are Impacted for the 2019 Performance Period?
CMS has identified the following quality measures requiring performance data to be suppressed for the last quarter of the performance period. Performance data would be limited to the first nine months (January 1–September 30) of the performance period:
Where Do I Go for Assistance
If you have questions regarding the International Classification of Diseases-10 (ICD-10) impact analysis, please direct them to the QPP for timely assistance. You can reach the QPP Service Center by:

QPP Participation Status Tool Now Includes Second Snapshot of 2019 Qualifying APM Participant and MIPS APMs Data

CMS updated the QPP Status Tool based on the second snapshot of data from Alternative Payment Model (APM) entities. The second snapshot includes data from Medicare Part B claims with dates of service between January 1, 2019 and June 30, 2019 . The tool includes 2019 Qualifying APM Participant (QP) and MIPS APM participation status.

To learn more about how CMS determines QP and APM participation status for each snapshot, please view the QP Methodology Fact Sheet. For more information on APMs and lists of current APM participants, visit the QPP APM webpages.

What Does QP Status Mean?

If you qualify as a QP, this means you are:
  • Eligible for the 5 percent APM incentive bonus; and
  • Exempt from participating in MIPS.

How Do I Check My QP or APM Participation Status?
To view your QP or APM participation status at the individual level:
 
To check your 2019 eligibility at the APM entity level:
  • Log into the CMS QPP website. Learn how by downloading the QPP Access User Guide.
  • Browse to the Taxpayer Identification Number(s) affiliated with your entity.
  • Access the details screen to view the eligibility status of every clinician based on their NPI.
Earn CME Credit by Completing APM Modules

CMS has posted five continuing medical education (CME) modules on APMs. You can access them by logging into your Medicare Learning Network (MLN) account or creating one at the MLN Learning Management System webpage. Once logged in, type the name of the module into the search bar at the top of the website to find it.

The new APMs CME modules include:

  • QPP 2019 Overview 
  • Transitioning to an Advanced APM: 2019 Update 
  • QPP for MIPS APMs in 2019 
  • QPP for Advanced APMs in 2019 
  • QPP: All-Payer Combination Option in 2019 

For More Information
  • Visit the CMS.gov MLN Web-Based Training webpage and log in to MLN to access the modules.
  • Visit the QPP Resource Library to review new and existing QPP resources.
  • Contact the QPP at QPP@cms.hhs.gov or 1.866.288.8292 (TTY: 1.877.715.6222). To receive assistance more quickly, consider calling during non-peak hours—before 10 a.m. and after 2 p.m. ET.
New Quality Payment Program (QPP)
Tools and Resources
QPP Frequently Asked Question of the Month
Question: What is the 2019 MIPS Opt-in and Voluntary Reporting Policy?

Answer: Beginning in 2019, there are two ways for clinicians to participate in MIPS if they are not required to participate. Clinicians can elect to opt-in or voluntarily report, as discussed in the 2019 MIPS Opt-In and Voluntary Reporting Policy Fact Sheet .
  • The opt-in policy, new for 2019, allows some clinicians who would otherwise be excluded from MIPS the opportunity to participate and earn a payment adjustment.
  • Clinicians who are either excluded from MIPS or not required to participate in MIPS can choose to voluntarily report MIPS measures and activities. If a clinician or group chooses to voluntarily report measures and activities for MIPS, they will receive performance feedback, allowing them to prepare for future years.
 
Question: Our practice elected to be a part of the virtual group for MIPS in 2019. Do we need to complete an application to elect to be a part of virtual group for MIPS in 2020?
 
Answer: Yes. A practice/group is required to apply every year to be a part of the virtual group. T o complete the election process and for further information, please refer to the 2020 Virtual Groups Toolkit (ZIP).
Upcoming Learning Forum Fridays (LFF) Events
November 8, 2019
 1 p.m. ET
Security Risk Analysis and Possible Strikes
Learning objectives:
  • Define the components of an SRA.
  • Discuss common challenges in preparing an SRA.
  • Identify tools and resources to develop an SRA.
December 13, 2019
 1 p.m. ET
Series Finale: QPP Champions Panel
Learning objectives:
  • Describe best practices to MIPS submission.
  • Identify lessons learned in MIPS reporting and preparation.
Did You Miss the October 11 LFF Webinar?
 
Download the webinar recording for QPP Home Plate: Grand Slam Your Performance Goals . The presentation slides are also located at https://www.hsag.com/lff .

Do not forget to register for upcoming webinars and browse past webinars.  
Centers for Medicare & Medicaid Services Updates
Upcoming MIPS Important Dates and Deadlines

  • December 31, 2019 — 2020 virtual group election period closes
  • January 2, 2020 — 2019 MIPS performance period data submission window opens
  • March 31, 2020 — 2019 MIPS performance period data submission window closes

To learn more, visit the QPP website and access the following resources:

2019 Final MIPS Eligibility Determination

2020 QPP Final Rule
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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 .
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.
Health Services Advisory Group