Your MIPS Action Plan: Step 5 – Selecting a Submission Method
September 21, 2017
Written by Sarah Leake
The Medicare Access and CHIP Reauthorization Act (MACRA) ruling provides options for submission methods in the four categories of the Merit-based Incentive Payment System (MIPS). The methods are like those that were available for Physician Quality Reporting System (PQRS), such as registry, electronic health records (EHR), and Qualified Clinical Data Registry (QCDR). Below is a chart showing the categories and the available methods for reporting. A clinician may choose a different method for each category depending upon what is most appropriate for their practice situation.
Here are some general explanations on the various methods for reporting.
Claims-based – This reporting method uses codes on Medicare claims to determine performance on measures and is available for only individual physician quality reporting.
EHR – If considering EHR reporting, it is imperative that you discuss with your EHR vendor their capabilities for reporting the MIPS data and specifically the electronic Clinical Quality Measures (eCQM). Some key items to clarify are:
- is the EHR certified and to what version (2014 or 2015),
- what eCQMs are available for reporting to determine if they are appropriate for your practice,
- is the vendor a direct submission vendor or will you need to submit on your own,
- is there an additional cost,
- what type of dashboard is available for monitoring and ultimately reporting MIPS data, and
- does the vendor offer a support group and individual reporting.
Qualified Registries – These entities submit the clinical data on patients to the Centers for Medicare & Medicaid Services (CMS) on behalf of clinicians. They provide varying degrees of assistance in the collection of the data. Key items to consider when searching for a Registry vendor are much like those for EHR reporting:
- what measures are available for reporting,
- what is the cost, normally per clinician,
- what assistance is available from the Registry,
- is Registry available to only special groups, and
- does the registry accept group and individual reporting.
Also, check with your EHR vendor as they may have the capability to report registry measures. CMS provides a list of approved MIPS 2017 Qualified Registries.
Qualified Clinical Data Registries (QCDRs) – The QCDR reporting option is different from a qualified registry because it is not limited to measures within the Quality Payment Program. The QCDR can develop and submit for CMS approval QCDR measures which often include specialty-specific measures. Specialists should reach out to their association and see if they have a QCDR specific to your specialty. Here is a link to the CMS MIPS 2017 QCDRs.
CMS Web Interface – This option is only available for groups of 25 or more. The group must report on a set of 15 quality Measures for 248 Medicare Beneficiaries and must be able to report on 12 months of quality data. Groups must have registered with CMS by June 30, 2017, to report this method.
The explanations of reporting methods emphasized the considerations for the Quality category reporting, but the Improvement Activity and Advancing Care Information have multiple options for reporting. If you have submitted for Meaningful Use in the past, the Attestation option is familiar and at no cost, but you may want to consider your vendor or a registry depending on the cost and ease of reporting. Remember, for the Cost category CMS will use claims data and does not require clinicians to submit anything.
March 31, 2017, is still months away, but remember that this is the last date of submission for all reporting methods across all MIPS performance categories.
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Bethel Smith says
I was not aware that there are different submission plans for MIPS. I wonder how much of the size of the medical practice weighs into the plan choice. There are certainly a lot more behind the scenes business decisions going on at medial practices than most know. https://macramonitor.com/mips-data-submission.html
Mountain Pacific says
Yes, there are several different methods that can be used to submit MIPS. There are many variables that should be considered when selecting a submission method. Our QPP experts have worked with thousands of providers to help them develop a customized action plan to be successful at reporting MIPS in a manner that is most reasonable for their clinic. Mountain-Pacific is a contractor with CMS and offers no cost technical assistance for small and large clinics reporting MIPS.
Ricky Ben says
The MIPS submission methods are different roads a clinician can take and reach destination MIPS. As a consultant at P3 Healthcare Solutions, we advise not to do it on your own and hire experts for MIPS. We often make mistakes when we are busy with the patients, and at the same time, we are selecting measures for submission.
Leave the job to the pros that are aware of what’s at stake here. We can get you the incentives along with a bonus for MIPS 2018, provided you contact us before April 2nd, 2019, make it 2 to 3 days before the deadline if you want to score in the 70s.
Those of you looking to score high in MIPS 2019, I’d suggest the MIPS Qualified Registry method as an easy way to connect with CMS on their terms and conditions.