Kim,
Thanks for beginning this incredibly important forum topic.
As we all know strategic planning to position our groups to optimize their MIPS scores is paramount to achieve the highest upward payment adjustment possible. Groups must use this upward payment adjustment to recoup their initial investment made to report their data through registry reporting as well as miscellaneous costs of all administrative work. In addition, groups are looking to offset all historical CMS cuts to the Medicare Part B fee schedule and upside risk assumed in participating with certain value-based payment models.
Any group that has been involved in the process to preparing for an upcoming MIPS performance year knows that it takes much time and effort to filter through the year over year changes to the QPP that are published in the final rule each November. From this point, the planning begins based on what groups know at that time.
Even the best forecasters of where the MIPS program is headed in the future could not possibly foreshadow CMS updating the quality measure benchmarking for PY 2020 6+ weeks into the new year. While this is an unprecedented move by CMS, we are left to ask ourselves why a check and balance of accountability, transparency and support does not seem to go both ways. CMS has historically published each year's original benchmarking the week between X-mas and New Year with the PY 2020 benchmarking published on New Year's Eve this year, hours before the start of this new performance year.
It is this very benchmarking that becomes the last piece of critical information groups need to finalize their planning, communicate to their coding teams, execute programming to assist in automating data extraction, communicate any measure changes to MIPS eligible clinicians, implement new measures, etc. With multiple MIPS team stakeholders involved we know this takes more than a couple of hours to execute the day before start of a new PY.
While this planning is butted up against the end of last year, we all find ways to be successful in all implementation necessary to begin reporting our chosen measure sets.
Fast forward 6+ week into this new 2020 PY. CMS, in an unprecedented move published updated benchmarks that have completely changed the game for groups that had just spent the last few months preparing for a new reporting year. We must encourage our strong radiology community to ask ourselves some obvious questions, "Is this fair?", "What gives CMS the liberty to do this?", "Is this ethical?", "How can quality healthcare show continuous improvement when the organization that governs this initiative is unaccountable to the eligible providers that bear this newfound, uphill burden 6+ weeks into a reporting period?", "Does CMS know the effect this move has on groups' original plans, while diminishing their opportunities to achieve optimal performance scoring while building their credibility as a provider that delivers the highest quality healthcare?", "Who does this updated benchmarking truly benefit?", "Finally, what efforts must our radiology community embark on to even the playing field CMS has preserved to monopolize?".
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Gregory D. Wertz MS
Director of Industry Research and Relations
Practice Manager
MBMS, LLC
State College, PA 16801
Mobile: (814) 203-0088
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Original Message:
Sent: 03-02-2020 10:41
From: Kim Smiley
Subject: Revised 2020 MIPS Benchmarks
Hello,
Has anyone had time to review the recent changes that have been made to the 2020 MIPS Historical Quality Benchmarks? If I am reading this correctly, Measure 146 and 406 are now topped out and have a seven point cap. This change was just made on 2/19/20.
Is this correct?
I thought Measure 146 was devalued in 2019, but revalued back to 10 points in 2020 and I am unsure why Measure 406 is now considered as topped out. It's only in its 2nd life cycle.
Here are the notes from QPP for the 2/19/20 version history.
Thanks!
Kim Smiley, CPC, RCC
Coding Manager
ph: (317) 328-7256 | fax: (317) 715-9955
kim@northwestradiology.com
