Individual clinicians and provider groups hoping to take advantage of the facility-based measurement for the 2020 Merit-based Incentive Payment System (MIPS) Quality and Cost performance categories can now check their facility-based status with the updated participation status tool on the Quality Payment Program website.
Facility-based measurement allows clinicians and groups the opportunity to receive scores in the Merit-based Incentive Payment System (MIPS) Quality and Cost performance categories based on the Hospital Value-Based Purchasing (VBP) Program score earned by their assigned facility.
To qualify for facility-based measurement in the 2020 MIPS performance year, individual clinicians must meet the following criteria:
- Billed at least 75% of their covered professional services in a place of service (POS) indicating a hospital setting (inpatient hospital (POS=21), on-campus outpatient hospital (POS=22), or emergency room (POS=23)) between October 1, 2018 and September 30, 2019;
- Billed at least one service in an inpatient hospital or emergency room between October 1, 2018 and September 30, 2019; and
- Can be assigned to a facility with a FY 2021 Hospital VBP Program score.
For now, clinicians will be identified as facility-based if they meet the first two requirements above and can be assigned to a facility with a FY 2020 Hospital VPB Program score (the most recent score available at this time). If the assigned facility does not end up having a FY 2021 Hospital VBP Program score, then the facility-based designation will not apply for 2020.
Groups and virtual groups qualify for facility-based measurement in the 2020 MIPS performance year when more than 75% of the clinicians in the practice/virtual group qualify for facility-based measurement as individuals.
How Does Facility-Based Measurement Work?
For 2020, the facility-based Quality and Cost performance category scores will be based on the 2021 Hospital VBP Program Total Performance Score (TPS) calculated from several different measures. The TPS is then translated into a MIPS program-specific score [automatic download] 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%
Submitting Additional MIPS Data
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. In fact, provider groups must submit data for the Improvement Activities and/or Promoting Interoperability performance categories to be able to receive facility-based Quality and Cost scores because that submission signals the intent to participate as a group.
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.
The same is true if an individual clinician is considered facility-based, but his non-facility-based group participates in MIPS as a group. CMS will assign the provider the higher final score of the two: a provider’s individual score (using facility-based measurement) or the group’s score.
For more information about the 2020 MIPS facility-based measurement, download the 2020 Facility-Based Measurement Quick Start Guide [automatic download]. To check your facility-based status, enter your NPI into the QPP Participation Status tool.
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