Under the new Medicare Quality Payment Program Merit-Based Incentive Payment System (MIPS), quality scoring is not an all-or-nothing process as it was in the sunsetting PQRS program. Six measures are required, including one outcome or high priority measure, with each earning up to 10 possible points. But each measure is scored individually and then added together and weighted for the final MIPS score. That means if, for instance, a provider submits only four measures, he’ll get points for the measures submitted, but not for the ones he did not. Which means at best, his score would be 40 out of 60.
But there’s a catch.
What if that provider submitted four measures instead of six because there were only four measures that applied to his practice? That’s where the new Eligible Measure Applicability (EMA) process comes in.
For providers who report quality data via claims or a qualified registry and report less than the required quality six measures for a program year, CMS will use EMA to determine whether or not additional measures applied and should have been reported. If not, the total possible score will be reduced to reflect the actual number of measures reported multiplied by 10 points each.
Here’s how EMA works.
Much like the PQRS Measure Applicability Validation process, EMA includes two steps.
- First, a Clinical Relation Test. Based on the one to five measures submitted, CMS will search for other clinically related quality measures that could have been submitted. This same criteria is applied if none of the measures submitted was an outcome or high priority measure. Based on the measures submitted, CMS will search for clinically related outcome or high priority quality measures that could have been submitted.
- Second, a Minimum Threshold Test. If any measures were found in step one, CMS will analyze Medicare claims submitted during the reporting period to see if the provider had at least 20 denominator eligible instances.
If additional measures are found and at least 20 eligible instances are identified, then the provider’s score will continue to be based on a total of six measures and 60 points possible. If additional measures are not found, or if the ones that are found do not pass the minimum threshold test, then the score will be based on the total number of measures reported multiplied by 10 points each.
EMA does not impact any other aspect of scoring, including case minimums which are necessary for earning beyond the minimum three points per meaures just for submitting any data at all. For more information about how MIPS is scored, check out this CIPROMS article.
For more information about the EMA process, download the MIPS EMA Materials Zip file with fact sheets and other resources.
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