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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