What is the Quality Performance Category in MIPS?
The Quality performance category within MIPS assesses health processes and outcomes through quality measures and is one of four performance categories upon which Eligible Clinicians (ECs) will be judged to determine future Medicare Part B payments by earning points for completion of measures. The MIPS Quality category is not a “pay-for-reporting” program and does not have a “satisfactory reporting requirement” to avoid the penalty.
Each quality measure is converted into a 10-point scoring system which enables the CMS to derive a quality score. A MIPS EC’s performance on quality measures is broken down into 10 "deciles," with each decile having a value of between 1 and 10 measure achievement points. A total of 60 measure achievement points is available for the Quality performance category, not including bonus points. CMS then compares a clinician's or group's performance on a quality measure to the performance levels in the national deciles. In other words, the data you submit for each quality measure is compared to a national benchmark in order to determine your Quality score, or number of points achieved for each quality measure. By using benchmarks, CMS is able to compare an EC's performance as it relates to that of their peers. The baseline period for deriving benchmarks will be two years prior to the performance year, which will enable CMS to publish measure benchmarks prior to the start of the relevant performance year. Each measure will typically earn between 3-10 points based on performance compared to a benchmark.
Am I required to report measures for the MIPS Quality Category?
For all CRNAs who are subject to MIPS reporting in 2019, reporting measures in the Quality category is highly recommended, because the baseline weighting is set to 45% of your MIPS final score. This means a significant portion of the Quality Performance Category weight will be used to calculate your MIPS Composite Score. Due to performance category exceptions and/or exemptions, your total performance category score may vary.
CRNAs can check their 2019 MIPS participation status with their National Provider Identification Number (NPI) by using the CMS MIPS Participation Status Tool. The look-up tool displays eligibility information for determination periods, with the first from October 1, 2017 through September 30, 2018; and the second from October 1, 2018 through September 30, 2019.
What are the full participation requirements for the Quality Category?
To fully participate in the Quality Performance Category, an eligible clinician (EC) must identify at least six quality measures—one of which is a high priority or outcome measure—and meet the data completeness requirement. Quality measures may be selected from the 2019 MIPS Anesthesia Specialty Measure Set, or the CMS Explore Quality Measures site. If fewer than six MIPS measures apply, CRNAs will need to identify alternative non-MIPS measures via a Qualified Clinical Data Registry (QCDR) in order to meet full participation for the Quality category.
To assure data completeness for selected quality measures, individual MIPS eligible clinicians or groups submitting data using QCDRs, qualified registries, or an electronic health record (EHR), must report on at least 60 percent of the MIPS eligible clinician's or group’s patients that meet the measure’s denominator criteria, regardless of payer for the performance period. CRNAs will achieve fewer points in the Quality category if they choose to only partially participate; in other words, if they submit fewer than six measures and/or not meet data completeness.
How do I achieve points for measures in the Quality Performance Category?
Quality measures that have no CMS set benchmark or do not meet the minimum 20 case requirement, will only receive 3 points. If a measure does not meet the 60% data completeness threshold, then only 1 point can be achieved, except for clinicians reporting from small practices (15 or fewer eligible clinicians). Measures that do not meet the data completeness criteria will earn 1 point, except for a measure submitted by a small practice, which will earn 3 points.
How does my performance in the Quality Category affect my final MIPS score?
CMS finalized the Quality Category weight at 45% in 2019 for ECs subject to all four performance categories. However, many CRNAs will be exempt from one or more categories, reweighting their Quality Performance Category weight on their overall MIPS final score. Most CRNAs will find that the Quality performance category will be reweighted up to 85% due to multiple CMS exceptions and/or exemptions.
- CRNAs will find themselves exempt from the Promoting Interoperablity (PI) category, increasing the Quality Category performance weight to 70%. However, should they choose, CRNAs may participate in the PI category and have their Quality Category weight remain at 45% and PI weight remain at 25%.
- CRNAs may likely also have an exception for the Cost Performance Category, weighted at 15%. This is because CRNAs do not provide services that trigger the HCPCS/CPT codes used to evaluate Total Cost per Capita (TPCC), Medicare Spending per Beneficiary (MSPB), and 8 new episode-based measures.
What is the performance period for the Quality Performance Category?
What are the deadlines for the 2019 MIPS reporting year?
The performance period begins on January 1, 2019 and ends December 31, 2019. To successfully participate in MIPS, CRNAs need to collect data for the reporting period designated for each performance category. For 2019 the Quality performance category reporting period is a full calendar year. CRNAs are encouraged to identify a reporting mechanism such as a Qualified Clinical Data Registry (QCDR) or “traditional” Qualified Registry to meet the 2019 reporting requirements. Once you have chosen your reporting mechanism, your QCDR or Qualified Registry has until March 22, 2020 to submit your quality data to CMS on your behalf.
What factors should I consider when attempting to identify measure for the 2019 MIPS Quality Performance Category?
When selecting measures for reporting, the following factors should be considered:
- Clinical conditions commonly treated
- Types of care delivered frequently – preventative, chronic, acute
- Settings where the care is delivered – office, emergency department, surgical suite
- Quality improvement goals for the year
- Other quality reporting programs in use or being considered
It is up to the individual EC or group to determine which measures are eligible to your practice. Modifications to MIPS measure specifications may undergo revisions and updates. CMS provides a list of these changes via the CMS Measure Specifications Manual and Supporting Documents. CMS states that “All stakeholders should be cognizant of the most up-to-date list and reference it for reporting purposes.” According to the manual a measure will consist of a numerator, denominator, and a rationale. The numerator describes the process or outcome required for performance measurement. The denominator identifies which cases or patient population the measure applies to through codes (e.g., ICD-10, CPT, HCPCS) and additional criteria. For verification purposes, it is important to identify these changes to assure that you, your group, billers, and/or vendors submitting on your behalf are meeting satisfactory reporting based on any updated measure specifications. It is also important to note that not all measures apply to every anesthesia setting or practice, and it is the responsibility of the CRNA to ultimately choose their measure.
The AANA cannot determine which measures may or may not apply to you and your practice. For this reason, the AANA encourages EPs to contact the CMS QualityNet Help Desk at (866) 288-8912 or Qnetsupport@hcqis.org to ensure you are reporting applicable measures.
What anesthesia specific measures are available and where can I find them?
CMS has compiled a 2019 MIPS Anesthesia Specialty Measure Set that CRNAs may choose from. Along with these MIPS measures, CRNAs may seek out additional measures developed by a Qualified Clinical Data Registry (QCDR). A QCDR is defined by CMS as a “CMS-approved entity that collects clinical data on behalf of clinicians for data submission.” Examples include, but are not limited to, regional collaboratives and specialty societies. CRNAs that choose a QCDR need to refer to the respective QCDR for measure specifications. Please refer to the 2019 QCDR list of vendor options.
The table below lists the 2019 MIPS anesthesia-specific measures that CRNAs may choose to report. These 2019 MIPS measures are targeted toward anesthesia providers. Please note that only 1 out of the 6 CMS 2019 MIPS anesthesia-specific measures can be reported via claims; therefore, this no longer a viable reporting option for CRNAs.
*Measure 463 is new for 2019
What 2019 MIPS reporting options can a CRNA choose from?
CRNAs may choose from the following reporting options to submit their quality data as individual EPs:
- Electronic Health Record (EHR) *if no EHR, check QCDR or QR
- CMS-Certified Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey Vendor
- Qualified Registry
- Qualified Clinical Data Registry (QCDR)
* Note: only one(1) out the 6 MIPS anesthesia-specific measures can be reported via claims; therefore, claims-based reporting is no longer a viable reporting option for CRNAs who work in traditional anesthesia.
Group practice reporting options for the 2019 MIPS reporting period include:
- Electronic Health Record (EHR)
- Qualified Registry
- Web Interface (for 25 or more EPs)
What is the difference between a Qualified Registry and a QCDR?
A Qualified Registry (QR) is capable of collecting and submitting MIPS quality data derived from MIPS measures to CMS on your behalf; however, QRs cannot collect and report out on non-MIPS measures. Download the 2019 CMS-approved List of Qualified Registries.
A Qualified Clinical Data Registry (QCDR) is defined by CMS as a “CMS-approved entity that collects clinical data on behalf of clinicians for data submission.” Examples include, but are not limited to, regional collaborative and specialty societies. QCDRs cannot be owned or managed by an individual, locally owned specialty group. The 2019 CMS-approved list of QCDRs can be found on the CMS Quality Payment Program Resource Library website.
The QCDR reporting option is different from a qualified registry because it is not limited to MIPS measures within the Quality Payment Program. The QCDR can host up to 30 “non-MIPS” measures approved by CMS for reporting as well. Measures submitted by a QCDR may include measures from one or more of the following categories:
- Current 2019 QCDR Measures (i.e., CMS approved non-MIPS Measures)
- Current 2019 MIPS measures
- Clinician and Group Consumer Assessment of Healthcare Providers and Systems (CAHPS), which must be reported via CAHPS certified vendor
- National Quality Forum (NQF) endorsed measures
- Measures used by boards or specialty societies
- Measures used by regional quality collaborations
- Other approved CMS measures