Rise Above the MIPS Data Delivery Gap

August 7, 2017

Great news! Clinicians are developing a Medicare Access and Chip Reauthorization Act (MACRA) strategy for Merit-based Incentive Payment System (MIPS) reporting for 2017. Don't forget to include strategies for rising above the data delivery gap. Many of my clients struggle to isolate, extract, and deliver data to CMS.

Remember there are options in 2017, determine your submission mechanism by aligning your current-state characteristics with the mechanisms strengths for best results.

1. Submission Mechanisms

Performance categories can be reported via different submission mechanisms, though many eligible clinicians and groups are glad to consolidate the work. Below are your options for submission mechanisms in each category:

2. 90-day period

In 2017, you are able to reach the maximum performance level by submitting 90 days of data in each performance category. You are allowed to submit data for different 90-day periods across the three categories. This means that you could submit data for the Quality category for June-August, and submit data for ACI from September-November.

Consider the minimum threshold for each numerator in the quality measures you will report on in 2017. Don't attempt 90-day period unless you exceed the requirements.

3. Group vs. Individual reporting

Although you can report on different 90-day periods for different performance categories, all clinicians within a TIN that is reporting as a group must use the same performance period for each performance category. This is consistent with how CMS evaluates groups overall, treating the group as a super-clinician, where all the group’s data is evaluated in the same way one clinician’s data would be evaluated.

Along those lines, all eligible clinicians within a group that is reporting as a group must report the same measures in all performance categories. All data within that group will be looked at as if the group is one super-clinician, which means that if a patient has an eligible encounter that puts them in the denominator of a measure, all clinicians are together responsible for meeting the numerator criteria in selected measures, regardless of which specialist the patient sees. This has been a point of concern for many multi-specialty groups, who are worried that specialists are responsible for providing care that is irrelevant to their specialty. The reasoning behind this requirement is that the group has collectively taken responsibility for the patient’s care. As a result, some multi-specialty groups are electing to report individually for all clinicians.

Partnering with Whittle Advisors can close the data delivery gap.

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