Quality Performance Category Overview
Quality Performance Category Weighting
The quality performance category is the most highly weighted category of MIPS. In 2018 Quality will have a weighting of 50% for most practices.
However, it will likely have a higher weighting for a significant number of practices. For example the Quality performance category’s weighting will increase to 60% for practices that do not meet the case minimum requirement for the Cost category of MIPS.
Hospital-based clinicians, MPs, PAs, and CNS’s are not obligated to submit data for the Promoting Interoperability (formerly referred to as Advancing Care Information). For these providers the 25% weighting of this category is shifted to quality, resulting in quality having a 75% weighting. (However, these groups still have the option of reporting their Promoting Interoperability data. If this option is chosen CMS will give the Promoting Interoperability category the same 25% weighting as most other practices.)
Scores in the quality category of MIPS are determined by performance on quality measures. Most practices will report data on six or more quality measures. Some specialties may not have six applicable measures to choose from. These groups may submit fewer than six measures. Additional information on how CMS determines if the practice has submitted data on all applicable quality measure is available at: Eligibility Measure Applicability (EMA) Process
The All Cause Readmission Measure
MIPS Quality scores for groups larger than 15 clinicians will also be partially determined by the “All Cause Readmission Measure.” The case minimum for this measure to be used for score determination is 200 cases. If this threshold is not met the performance will be based on the submitted MIPS measure data. If the case minimum is met groups of this size will have their MIPS quality performance score determined by performance on seven measures. There is no reporting requirement for the All Cause Readmission Measure as CMS will base performance upon claims data.
There are over 270 quality measures to choose from for the 2018 performance year. Measures are classified into: Process Measures, Outcome Measures, and High Priority Measures. When selecting measures practices should include at least one outcome measure. If no outcome measures are applicable to the type of care provided by the practice the practice needs to submit at least one high priority measure.
The specific measures available for use in 2018 are available via the CMS 2018 Resource Library. Measures approved in the 2018 Quality Payment Program Final Rule as well as measures developed by Qualified Clinical Data Registries (QCDRs) may be used for reporting performance in 2018. To use QCDR measures, however, practices must use a QCDR as their reporting mechanism.
2018 Quality Reporting Period
In 2018 the reporting period for the quality measures is 12 months in duration, from January 1, 2018 to December 31, 2018. Data can be collected retrospectively.
Reporting Mechanisms for Quality Performance
The following MIPS Quality reporting mechanisms are available:
- Limited to clinicians reporting as individuals
- Practices need to attach quality data codes to claim forms
- Each clinician should report 60% of all measure applicable Medicare beneficiaries seen in 2018
- Qualified Registries/QCDR’s
- Applicable to clinicians reporting as individuals and those reporting as groups, including virtual groups.
- Practices need to report 60% of all measure applicable patients regardless of payer
- Electronic Health Records (EHRs)
- EHR’s may report data directly to CMS
- Applicable to clinicians reporting as individuals and groups, including virtual groups.
- Practices need to report 60% of all measure applicable patients regardless of payer
- There are a relatively small number of measures that are applicable for reporting through this mechanism
- CMS Web Interface
- Limited to groups of 25 or more clinicians
- Medicare patient data only
- Based on random sampling of 248 patients and 15 predesignated quality measures.
Some measures can only be reported through one or two of the above reporting mechanisms. In 2018 the EHR reporting mechanism has the fewest number of measures available as compared to the Claims and Registry reporting mechanisms.
In the first two years of the Quality Payment Program CMS required that all quality measure data be submitted through the same reporting mechanism. This will likely change in 2019 as CMS has proposed allowing practices to report quality measure data via multiple reporting mechanisms.
Data Completeness Requirement
CMS has a data completeness requirement of 60% of all patients seen during the calendar year. As noted above, when reporting via the claims mechanism this is limited to Medicare Part B beneficiaries only. When reporting via the qualified registry, QCDR, or EHR reporting mechanisms the data completeness requirement is applicable to all patients applicable for a measure, regardless of payer. The CMS Web Interface reporting mechanism requires at least 248 Medicare patients randomly selected by CMS to be reported for each measure.
If the data completeness requirement is not met large practices of 16 or more clinicians reporting as group will receive a score of 1 point for the measure, regardless of performance. Practices of 15 or fewer clinicians reporting as a group and clinicians reporting as individuals will receive 3 points.
Case Minimum Requirement
When reporting the denominator for each submitted MIPS measure must reach a minimum case minimum threshold of 20 or more encounters or procedures. If the case minimum requirement is not met the practice will receive a score of 3 points for the measure.
CMS collects performance data on measures and establishes benchmarks for each measure and reporting mechanism when enough data is available. For 2018 the benchmarks values are based on performance in the PQRS program in 2016. The benchmarks vary by reporting mechanism. A number of measures are “topped out” or nearly topped out, making performance challenging. Benchmarks should be reviewed closely when choosing measures as they may adversely impact performance.
When CMS does not have enough data to establish benchmarks the measure will be identified as not having a benchmark at the beginning of the performance year. It may still be reported by the practice but if CMS does not receive enough data to calculate a benchmark during the performance year the practice will receive a score of 3 points. This is regardless of how well the practice actually performs on the measure. However, if CMS does receive adequate data to determine benchmarks for the measure the benchmarks may or may not be more favorable than they are for other quality measures.
Additional information about benchmarks and how they are used to determine the final score for the measure is available: Quality Measures Benchmarks
A table of the the 2018 MIPS measures and their benchmarks is available: 2018 MIPS Quality Measure Benchmarks
CMS Web Interface Reporting Mechanism
This is an option available to eligible practices of 25 or more eligible clinicians. This mechanism requires that performance on 15 preselected measures be reported. It is limited to 248 randomly selected Medicare beneficiaries with conditions/encounters applicable to one or more of the 15 measures throughout the performance year. Practices must notify CMS through a registration process that they are choosing to report through the CMS Web interface between April 1, 2018 and June 30, 2018 to be eligible for reporting through this mechanism.
Benchmarks used for the CMS Web Interface measures are the same as those used for Medicare Shared Savings Program (i.e., CMS Accountable Care Organizations).
Quality Measure Bonus Points
There are three sources of bonus points for the Quality performance category of MIPS in 2018:
- The End-to-End Electronic Reporting Bonus: Practices will receive 1 bonus point per measure for reporting quality data directly from a certified EHR to a Qualified Registry, QCDR, or via the CMS Web Interface. These points are added to groups total score for the quality performance category.
- Additional Bonus Points for Submitting Additional Outcome or High-Priority Measures: Each additional outcome measure submitted (in addition to the first outcome measure submitted) will receive a two-point bonus. Each additional high-priority measure (in addition to an outcome measure or another high-priority measure) submitted will receive 1 bonus point per measures. The maximum number of bonus points available through this mechanism is five.
- Bonuses for Improvement in Quality Performance Category Scoring: Practices can earn up to 10 percentage points based on the rate of improvement in the Quality performance category when compared to the previous year. CMS needs to be able to identify that the same provides/group are reporting in the current and previous year based on an assessment (e.g., same group of NPI/TIN combinations).
Additional Quality Performance Category Information
Quality Measure Reporting Frequency Labels