Read the Latest Issue of STATLINE
October 2, 2018
In This Issue:
CMS’ Errors in 2017 MIPS Scores Lead to Extended Review Period
Earlier this summer, eligible clinicians and groups began reviewing their 2017 Merit-based Incentive Payment System (MIPS) final scores on the Quality Payment Program website, and requesting targeted reviews from the Centers for Medicare & Medicaid Services (CMS) if there was an error with their 2019 MIPS payment adjustment calculation. The CMS received many requests for targeted reviews, which caused the agency to evaluate further concerns regarding the scores.
Based on these requests, the CMS identified errors in the scoring logic and extended the targeted review deadline to October 15, 2018, at 8:00 PM EDT. Further, correcting the scoring mistakes resulted in reductions to associated 2019 MIPS payment adjustments for most clinicians.
The CMS did not disclose how many physicians were affected, nor did the agency send out notifications to participating physicians. Therefore, the CAP urges all pathologists to review your performance feedback on the Quality Payment Program website and report any errors with your 2019 MIPS payment adjustment calculation.
Check if Cost Measures Were Attributed to You
The CMS has suggested that many non-patient-facing clinicians may not meet the case minimum for any measure included under the MIPS Cost category to be counted. However, non-patient-facing clinicians are not expressly exempted from the cost category. A pathologist meeting the minimum number of cases would have these cost measures attributed to him or her and a Cost performance score assigned. It is anticipated that most pathologists will not be attributed any cost cases, and instead have the Cost category reweighted to the Quality category. However, some large practices may have a Cost score.
The CAP strongly encourages all participating pathologists to check their 2017 MIPS performance feedback to see if you were attributed to any Cost measures.
Although Cost is reweighted to quality in 2017, if the CMS can calculate a cost score for you, it has been provided as a courtesy in your feedback report. If you find that the CMS attributed you or your practice to a Cost measure in 2017, the CAP would like to know. Please share a copy of your 2017 MIPS Feedback report with MIPS@cap.org. If you were attributed cost on your report, we also suggest you request a “targeted review” from the CMS so you can better understand which cases triggered the Cost score. Therefore, you can better understand how to improve this score over time.
The CMS has resources available on the Quality Payment Program Resource Library to help clinicians understand their performance feedback and the targeted review process. If you are in need of additional assistance, please reach out to the Quality Payment Program Service Center by phone at 1-866-288-8292, (TTY) 1-877-715-6222 or by email at QPP@cms.hhs.gov.
Prepare for Potential Inclusion in Cost Measures for MIPS 2020
The CMS and a contractor, Acumen, LLC, will conduct field testing in October 2018 for 13 new Cost measures for their potential use in the MIPS beginning in 2020 or later.
The CMS has suggested that many non-patient-facing clinicians, like pathologists, may not have enough measures or meet the case minimum for any Cost measure to be counted. However, non-patient-facing clinicians are not expressly exempted from the Cost category. As such, a pathologist, whether patient-facing or not, meeting the minimum number of cases would have these cost measures attributed and a Cost performance score assigned.
The CAP strongly encourages pathologists to check if the CMS provides you with field test reports, which will contain information on your Cost performance for these new measures. The field test reports will be available for to review starting Wednesday, October 3 to October 31, 2018.
In order to participate in the field testing, you must configure your Enterprise Identity Management (EIDM) account on the CMS Enterprise Portal as you or your clinician group might receive a report. A pathologist’s authorized representative can create an account or ensure that your existing EIDM account has the 'Physician Quality and Value Programs' role using this guide. Further details about field testing will be provided in the coming weeks.
If you have any questions or require assistance with your EIDM account, please contact the Quality Payment Program Service Center via telephone at 1-866-288-8292 or via email at QPP@cms.hhs.gov.
Decoding MIPS Webinar Series
Check out the latest webinar recording
As part of our ongoing commitment to ensure pathologists can successfully participate in new and evolving payment models, the CAP offers MIPS educational webinars.
The third webinar recording, Pathologist Improvement Activities Under MIPS, is available now to download. If you missed it, Diana Cardona, MD, FCAP, reviewed the improvement activities most relevant to pathologists.
The next webinar in the series is open for registration is the 2019 Final Medicare Policy and Payment Changes on November 9, 2018 at 11 AM ET. As one of the most watched webinars the CAP offers, learn as CAP experts review the final regulations to the 2019 Medicare Physician Fee Schedule and the Quality Payment Program.
Donald S. Karcher, MD, FCAP
Chair of the Council on Government and Professional Affairs
Emily E. Volk, MD, FCAP
Vice-Chair of the Council on Government and Professional Affairs
Chair of the CAP Clinical Data Registry Ad-Hoc Committee
W. Stephen Black-Schaffer MD, FCAP
Chair of the CAP Economic Affairs Committee
Other upcoming webinars in the MIPS series are open for registration:
Quality Measures that Will Improve Your MIPS Score
Tuesday, December 4, 2018, Noon ET
Diana Cardona, MD, FCAP
Examine ways of improving your performance and MIPS scores using CAP-developed quality measures.
Steps to Take Before Reporting MIPS Data
Tuesday, January 8, 2019, 3PM ET
Emily Volk, MD, MBA, FCAP
Discover ways of maximizing your scoring for 2018 before submitting results to CMS.
Uncover Ways to Impact Your Income at CAP18
Are you being paid fairly for the services you provide? Payment for pathology services has a direct impact on the success of your practice. Do you know who makes these decisions—and what criteria they use? Are there steps you can take to ensure fair compensation? These topics and more will be explored at CAP18.
- MACRAscopic Analysis of the New Quality Payment Program: Maximize Reimbursement While Demonstrating Value (S1620)
- How Is My Payment Determined for Pathology Services? Non-CME course (STA008)
- The CAP’s Policy and Advocacy Agenda (STA010)
- The Role of Pathologists in Population Health: An Interactive Discussion (STA011)
- What You Need to Know About the CAP’s Pathologists Quality Registry Non-CME course
- Lunch Roundtables
- Current Payment Policy Challenges in Pathology Practice (R1691)
- My Surgical Pathology and Cytopathology Coding Dilemmas: Getting It Right—An Advanced Discussion (R1690)
Learning Pavilion Sessions
- Understanding and Maximizing your MIPS Score
- How to Keep Your Practice Afloat While Reimbursement Rates Decline
CAP Exhibit Booth
- Pathologists Quality Registry Demos
- MIPS Resources for Pathologists
- Billing and Cost Assessment Toolkits
Registration is now open for vital CAP policy and advocacy courses and roundtable discussions during CAP18.