Facility-based physicians and other eligible clinicians whose practice takes place primarily in a hospital setting have a new way to meet reporting requirements for the Merit-based Incentive Payment System (MIPS) for the 2019 performance year.
How It Works
These facility-based providers participating as individuals, virtual groups, and groups have the option of tapping into their facility’s Hospital VBP Program for their Quality and Cost performance category scores. For 2019, the facility-based Quality and Cost performance category scores will be based on the 2020 Hospital VBP Program Total Performance Score (TPS) calculated from 12 different measures. The TPS is then translated into a MIPS program-specific score for the Quality and Cost performance categories using a two-step process:
- Step 1: Establish percentile performance compared to other hospitals participating in the Hospital VBP Program.
- Step 2: Calculate the performance score for the MIPS Quality and Cost performance categories associated with the same percentile performance under MIPS.
Once the TPS scores are translated into MIPS scores, the MIPS Final Score will be calculated in the same manner as those that were not facility-based, using the following category weights:
- Quality: 45%
- Cost: 15%
- Promoting Interoperability: 25%
- Improvement Activities: 15%
So Do Facility-Based Clinicians Submit Anything?
Facility-based measurement applies only to the quality and cost performance categories. To maximize their final score, facility-based individuals, virtual groups, and groups will need to collect and submit data for the Improvement Activities and Promoting Interoperability performance categories. However, MIPS scoring rules for special statuses and approved exceptions also apply to facility-based clinicians. For instance, hospital-based eligible clinicians are not accountable for the promoting interoperability category. In their case, the PI category receives 0 weight and the 25% is reallocated to the quality performance category when calculating the final score.
Also, eligible facility-based clinicians can still submit data for the Quality performance category as an individual, group, or virtual group if they think they can achieve a higher score using another submission method. In that case, CMS will calculate the Quality and Cost performance scores using both the facility-based measurement and the traditional MIPS submission formula and use whichever performance scores are higher.
How Does CMS Determine Who Is Facility-Based?
To determine which clinicians, virtual groups, and groups will be considered facility-based for the 2019 performance year, CMS will look at Medicare Part B claims billed between October 1, 2017 and September 30, 2018 (including a 30-day claims run out). MIPS eligible clinicians are considered facility-based using the following criteria:
- Billed at least 75 percent of your covered professional services in a hospital setting;
- Billed at least one service in an inpatient hospital or emergency room; and
- Can be attributed to a facility with a Hospital Value-based Purchasing (VBP) score.
CMS will identify groups and virtual groups as facility-based if 75 percent or more of the MIPS eligible clinicians in a group or virtual group are deemed facility-based. Groups and virtual groups will be attributed to the hospital at which the plurality of their clinicians are attributed as individuals.
Clinicians can learn whether CMS considers them facility-based by entering their data in the QPP Participation Status lookup tool. CMS also is offering a facility-based preview to allow providers to see what they their 2019 Quality and Cost performance category scores could look like using earlier data from the Hospital VBP. It’s important to note that these are not your final 2019 Quality and Cost performance category scores but rather a snapshot to see how you might potentially fare using this reporting option.
You can access your Facility Based Preview using the following steps:
- Sign into the QPP website. Don’t have an account? Review the QPP Access User Guide.
- From the Home page, click Preview Facility Score (or click the Facility Based Preview link in the left-hand navigation).
Need More Info?
To learn more about facility-based measurement for MIPS in 2019, check out the following resources from CMS:
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