MIPS Mastery, Chapter 5

MIPS Mastery is a seven-part series on optimizing performance under the Merit-Based Incentive Payment System, originally produced by PYA.

What Are the Four Components that Comprise the CPS and How Are These Scores Calculated?

1. Quality
The MIPS quality performance reporting requirements are less onerous than the current PQRS
requirements. An individual Clinician or group must report on at least six quality measures (as compared to the nine measures now required for PQRS reporting). 

The individual or group may select measures from the master measures list (Table A in the appendix to the proposed rule) or from the specialty-specific measure lists (Table E in the appendix to the proposed rule. Note that lists are provided for only 23 specialties; all other specialties must select from the master measures list.) 

Of the six measures, one must be from the ten identified “cross-cutting measures” listed in Table C in the appendix to the proposed rule. These measures relate to preventive care and screening, advance care plans, current medications list, and patient satisfaction. However, a non-patient-facing Clinician (an individual or group that bills for 25 or fewer patient-facing encounters during the performance year) is exempt from this requirement. 

Another one of the six reported measures must be categorized as an outcome measure. If an individual or group is utilizing a specialty-specific list that does not include any outcome measures, the Clinician or group must report on a measure categorized as a high-priority measure. The aforementioned tables include measure types and priority levels. 

Although CMS only requires reporting on six measures, a Clinician or a group may elect to report on additional measures. CMS will select the best six scores to calculate the quality component. Thus, reporting on additional measures may give a provider a better opportunity to earn a higher overall score. 

For 2017, CMS intends to include up to three populationbased measures derived from claims data in calculating Clinician and group quality scores. These measures are detailed in Table B of the appendix to the proposed rule.

For each measure on the master measures list, CMS
will establish a separate benchmark based on national performance during a baseline period. For those measures for which there is no historical data (e.g., new measures), CMS will use performance year data to establish the benchmarks. 

CMS will break baseline-period performance into deciles. Then, CMS will compare a Clinician’s or group’s actual performance to those deciles to determine the number of points to be assigned to the Clinician or group for that measure. CMS offers the following example of point assignment based on decile scoring:

A Clinician or group may earn bonus points to increase its overall performance measures score by up to 10%. Specifically, a Clinician or group may earn 2 points by reporting an additional outcome or patient experience measures or one point by reporting another high priority measure. Also, a Clinician or group may earn one additional point for every measure reported using a certified EHR for end-to-end electronic reporting.

Groups or individual Clinicians who choose to report via QCDRs, qualified registries, or EHRs must report on at least 90% of all patients who meet denominator criteria. Reporting on non-Medicare patients is a significant change from PQRS requirements. This requirement also may impact benchmarks for various quality measures that now include non-Medicare patients.

2. Advancing Care Information

Advancing care information is CMS’ new (and improved) version of meaningful use. A Clinician’s or group’s score in this category is a combination of a base score and a performance score.

To earn up to the 50 possible base score points, a Clinician or group must simply provide a (non-zero) numerator/denominator or yes/no response on specific measures tied to six objectives:

  1. Protection of patient health information
  2. Electronic prescribing
  3. Patient electronic access
  4. Coordination of care through patient engagement
  5. Health information exchange
  6. Public health and clinical data registry reporting

A “yes” response to the “protection of patient health information” objective is required to receive any points in the advancing care information category. And, unlike meaningful use, providers will not be required to report on clinical decision support or computerized provider order entry. Instead, a provider need only report to a public health immunization registry.

A provider may earn up to 80 advancing care information performance score points. Any provider who scores 100 or more total points will receive full credit under the
advancing care information category. These points are based on reported results for measures tied to three objectives: patient electronic access, coordination of patient care through patient engagement, and health information exchange.

For those Clinicians for whom these measures and objectives are not relevant (e.g., hospital-based physicians), this category is weighted at zero, with corresponding adjustments to the remaining categories’ weights.

3. Clinical Practice Improvement Activities (CPIA) 

In the proposed rule , CMS has listed more than 90 CPIAs for which Clinicians may receive credit, with a specific number of points assigned to each. Clinicians or groups that certify engagement in activities totaling 60 points will receive full credit in this category.

There are a few exceptions to the standard scoring criteria for CPIA. For Clinicians that are non-patient-facing and/or are located in rural areas or health professional shortage areas (HPSAs), each activity is worth 30 points. Thus, these Clinicians need report only two activities to get full CPIA credit.

Clinicians who participate in an APM automatically receive 30 (of 60) CPIA points. Lastly, groups that have a formal patient-centered medical home designation automatically receive 60 (of 60) CPIA points.

4. Resource Use

For 2017, Clinicians are not required to submit any data relating to the resource use category. Instead, CMS will use claims data to calculate scores on these measures.

First, CMS will calculate the total per capita costs and the Medicare Spending Per Beneficiaries Measures now utilized under the VM Program. However, CMS proposes to modify the manner in which it attributes beneficiaries to a Clinician or group to more accurately reflect providers’ roles in patients’ care.

Second, CMS proposes to use new episode-based measures in lieu of the total per capita cost measure for specific populations now used in the VM Program. Some (but not all) of the 41 proposed episode-based measures have recently been included in the Physician Value Modifier Program feedback reports (for informational purposes only). These episode-based measures have been identified as high-cost, high-variability in resource use. The list of 41 measures is included in the proposed rule; however, CMS may only finalize a subset of the measures.

Read Chapter 4

Read Chapter 6

Martie Ross, Principal with PYA Consulting