Despite COVID-19: Providers Should Not Lose Sight of MIPS Compliance


Courtney Tesvich, VP of Regulatory at Nextech

When 2020 began, no one anticipated that complying with the Merit-based Incentive Payment System (MIPS)—the flagship payment model of the Centers for Medicare & Medicaid Services (CMS) Quality Payment Program (QPP)—would look so different halfway through the year. Like many other things, the COVID-19 crisis has delayed, diverted, or derailed many organizations’ reporting efforts and capabilities. Lower procedure volumes, new remote work scenarios, and shifting priorities have taken attention away from MIPS work. 

Despite the disruptions and uncertainties associated with the pandemic, healthcare organizations should not lose track of MIPS compliance and the program’s intent to improve care quality, reduce costs, and facilitate interoperability. Here are a few strategies for keeping a MIPS program top of mind. 

Understand the immediate effects of the pandemic on MIPS reporting 

Due to COVID-19, CMS granted several 2019 data reporting exceptions and extensions to clinicians and providers participating in Medicare quality reporting programs. These concessions were enacted to let providers focus 100% of their resources on caring for and ensuring the health and safety of patients and staff during the early weeks of the crisis. For the 2020 MIPS performance period, CMS has also chosen to use the Extreme and Uncontrollable Circumstances policy to allow requests to reweight any or all of the MIPS performance categories to 0%.

Clinicians and groups can complete the application any time before the end of this performance year. If practices are granted reweighting one or more categories but submit data during the attestation period, the reweighting will be void and the practice will receive the score earned in the categories for which they submit data

Seize the opportunity to improve interoperability 

Interoperability is a key area that organizations were focused on before the crisis, and this work still warrants attention. If an organization is not on the front lines of the COVID-19 response, it should use this time to shore up communications with other entities so, once things return to “normal,” it will be well prepared to seamlessly exchange information with peer organizations. 

Establishing processes for sending and receiving care summaries via direct messaging is important for practices to earn a high score in the Promoting Interoperability category. Direct messaging is a HIPAA-compliant method for securely exchanging health information between providers, which functions as an email but is much more secure due to encryption. A regular pain point organizations face is being unable to obtain direct messaging addresses from peer organizations, including referral partners.

To assist providers in this area, the Office of the National Coordinator for Health Information Technology (ONC) and CMS has created a mandatory centralized directory of provider electronic data exchange addresses published by the National Plan & Provider Enumeration System (NPPES). The NPPES directory is searchable through a public API and allows providers to look up the direct messaging addresses for other providers. To meet current interoperability requirements, providers must have entered their direct messaging address into the system by June 30, 2020. If they haven’t done so, the provider could be publicly reported for failure to comply with the requirement, which could constitute information blocking. 

Take time now to ensure direct messaging addresses have been entered correctly for all members of your practice. This is also a good time to begin reaching out to top referral sources to make sure they are also prepared to send and receive information.

Look for ways to streamline quality reporting 

Over the next few months, the focus will return to quality measure reporting. As such, it’s wise to take advantage of this time to ensure solid documentation and reporting methods. Electronic medical records (EMRs) can be helpful in streamlining these efforts.

For example, dropdown menus with frequently used descriptions and automated coding can enable greater accuracy and specificity while easing the documentation process for providers. Customizable screens that can be configured to include specialty-specific choices based on patient history and problem list can also smooth documentation and coding, especially if screen layouts mirror favored workflow.

Regarding MIPS compliance in particular, it can be helpful to use tools that offer predictive charting. This feature determines whether a patient qualifies for preselected MIPS measures in real-time and presents the provider with data fields related to those items during the patient encounter—allowing the physician to collect the appropriate information without adding additional charting time later on. 

With respect to reporting, providers may benefit from using their certified EMR in addition to reporting through a registry. At the beginning of the MIPS program, providers could report through both a registry and EMR directly and would be scored separately for their quality category through each method. They would then be awarded the higher score of the two. This method had the potential to leave some high-scoring measures on the table.

Beginning in 2019, providers reporting through both registry and EMR direct are scored across the two methods. CMS uses the six highest scoring measures between the two reporting sets to calculate the provider’s or group’s quality score, potentially resulting in a higher score than the provider would earn by reporting through either method alone. 

A knowledgeable partner can pave the way to better performance

COVID-19 has impacted healthcare like no other event in recent history, and it’s not surprising that MIPS compliance has taken a back seat to more pressing concerns. However, providers still have the opportunity to make meaningful progress in this area. By working with a technology partner that keeps up with the current requirements and offers strategies and solutions for optimizing data collection and reporting, a provider can realize solid MIPS performance during and beyond this unprecedented time.


About Courtney Tesvich, VP of Regulatory at Nextech

Courtney is a Registered Nurse with more than 20 years in the healthcare field, 15 of which have been focused on quality improvements and regulatory compliance. As VP of Regulatory at Nextech, Courtney is responsible for ensuring that Nextech’s products meet government certification requirements and client needs related to the regulatory environment.  


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