Medicare Compliance & Reimbursement

Tip: Check your performance feedback ASAP.

Right now, your practice is probably focused on 2019 Merit-based Incentive Payment System (MIPS) measures and submissions. But you may want to backtrack and take a look at 2018’s results to ensure your future Medicare payment is in the positive.

What: The Centers for Medicare and Medicaid Services (CMS) recently released providers’ 2018 performance feedback and final scores for perusal.

Details: The 2018 MIPS submissions can be viewed on the Quality Payment Program (QPP) website through the HCQIS Access Roles and Profile (HARP) system with your MIPS credentials. Your feedback includes your payment adjustments — positive, negative, and/or neutral — that impact your 2020 Medicare payment.

Reminder: If you didn’t switch over to HARP when the Enterprise Identity Data Management System (EIDM) was dismantled back in January, you’ll need to do that first before you can check out your MIPS 2018 data or request a targeted review (see Medicare Compliance & Reimbursement, Vol. 45, No. 1).

MIPS APMs: Plus, the 2018 MIPS Alternative Payment Model (APM) entity data is available for review, too. According to CMS, the 2018 information covers participants under the following MIPS APM models:

• Medicare Shared Savings Program Accountable Care Organization (ACO)
• Next Generation ACO
• Comprehensive Primary Care Plus
• Oncology Care Model
• Comprehensive ESRD Care

“Under the MIPS APM scoring standard, the performance feedback will be based on the APM entity score, and is applicable to all MIPS eligible clinicians within the APM entity. This feedback and score does not have any impact on assessments performed by the specific model,” explains CMS.

Know the Targeted Review Basics

If you’re a MIPS eligible clinician, group, virtual group, or part of an APM and believe there are final score or feedback errors, you can request a targeted review of your 2018 results. During this process and according to what you’ve requested to be reviewed, CMS will look into one of five categories:

• Submissions’ errors
• Eligibility or special status 
• Measures’ issues
• Extreme and uncontrollable circumstances
• General issues

According to the QPP targeted review frequently-asked-questions (FAQs) set, CMS will not take up review requests for things like MIPS methodology, performance standards, and identification of measures on sites like Physician Compare.

Consider these five important factors before you submit a targeted review:

1. _Contact person: Choose wisely who will submit your targeted review form for your practice. The submitter will be the primary point of contact for follow-up requests.

2. _Issue: Determine an issue category and back up your request with a comprehensive explanation. 

3. _Documentation: Compile your MIPS 2018 supporting documentation now. Performance data, EHR extracts, third party information, proof of participation, and more might be requested, the QPP guidance suggests.

4. _Privacy: Encrypt and password protect your supporting documentation, keeping privacy in mind.

5. _Updates: Check your contact email for targeted review results. If you want the current status on your case, call QPP at 1-866-288-8292 and have your targeted review request number handy, the FAQ indicates.

If CMS finds errors and changes are made to your final score and 2020 payment, remember that “targeted review decisions are final and not eligible for further review,” the agency reminds.

The deadline to request a MIPS 2018 targeted review is Sept. 30, 2019.

Resource: Sign in with your HARP or MIPS credentials at  https://qpp.cms.gov/login to review your MIPS 2018 data.