Will all levels of a Patient-Centered Medical Home receive full credit for Clinical Practice Improvement Activities (CPIA)?

Yes.  As proposed, CMS is requiring that for MIPS purposes, a patient-centered medical home will be recognized if it is a nationally recognized accredited patient-centered medical home, a Medicaid Medical Home Model, or a Medical Home Model. The NCQA Patient-Centered Specialty Recognition will also be recognized, which qualifies as a comparable specialty practice.

Nationally recognized accredited patient-centered medical homes are recognized if they are accredited by:

  • Accreditation Association for Ambulatory Health Care

  • National Committee for Quality Assurance (NCQA) PCMH recognition

  • Joint Commission Designation

  • Utilization Review Accreditation Commission (URAC)

Is there a resource that describes how the data in 2017 will be pulled to calculate the composite scores, which in turn will determine the MIPS payment adjustment in 2019?

There are a variety of options to submit data to CMS for each of the four performance categories.  These options will vary based on whether an individual or a group is reporting the data.

  • Quality measures will be reported through Claims, Qualified Clinical Data Registry (QCDR), Qualified Registry, EHR Vendors, and CAHPS.

  • Performance in the resource use performance category would be assessed using measures based on administrative Medicare claims data.

  • For the CPIA performance category, CMS is proposing using the qualified registry, EHR, QCDR, CMS Web Interface, and attestation data submission mechanisms.

  • For Advancing Care Information, CMS is proposing to collect the data via Attestation, QCDR, Qualified Registry, EHR Vendor, and the CMS Web Interface for groups of 25 or more (GPRO).

Regarding the Advanced APM payment threshold, does each individual Eligible Provider need to meet the 25% payment threshold, or it is calculated at the group or ACO level?

CMS is proposing that an eligible clinician’s Qualified Participant status for a given payment year would be based on a collective evaluation of a group consisting of all eligible clinicians participating in an Advanced APM Entity. If the eligible clinicians in the Advanced APM Entity collectively meet the QP Payment Amount Threshold, QP Patient Count Threshold, Partial QP Payment Amount Threshold, or Partial QP Patient Count Threshold, CMS is proposing that all of those eligible clinicians in the group defined by the Advanced APM Entity would receive the QP status for the relevant payment year.

Will all physicians’ MIPS scores be reported on the Physician Compare website, even if they are in an APM?

MACRA requires that performance and participation information under MIPS and advanced APMs be made available for public reporting on the Physician Compare website. MACRA requires that the information be presented in an easily understandable format.  It also requires that information on individual MIPS eligible clinician and groups’ performance information be provided, including:

  • Names of eligible clinician’s in Advanced APMs and, to the extent feasible, the names of such Advanced APMs and the performance of such models

  • The MIPS eligible clinician’s composite performance score (CPS)

  • The MIPS eligible clinician’s performance under each MIPS performance category (quality, resource use, CPIA and advancing care information)

  • Periodically post-aggregate information on the MIPS, including the range of composite scores for all MIPS eligible clinicians and the range of the performance of all MIPS eligible clinician’s with respect to each performance category

How are rural practices designated?  Does the rule define “rural?”

CMS is proposing to define rural areas at 414.1305 as “clinicians in counties designated as micropolitan or non-Core Based Statistical Areas (CBSAs), using HRSA’s 2014–2015 Area Health Resource File.

Are groups that report quality measures under MIPS limited to a number of measures or are they required to pick measures for each specialty?

No. Groups are neither limited to a number of measures nor are they required to report measures for specialties.

MIPS-eligible clinicians and groups will have to select their measures from either the list of all MIPS measures in Table A or a set of specialty-specific measure set in Table E. CMS is proposing to require the MIPS eligible clinician or group to report at least six measures, including one cross-cutting measure (if patient-facing) found in Table C and at least one outcome measure. If an applicable outcome measure is not available, CMS is proposing that the MIPS-eligible clinicians or groups would be required to report one other high-priority measure (appropriate use, patient safety, efficiency, patient experience, and care coordination measures) in lieu of an outcome measure. Data submission and completeness requirements vary by the submission mechanism and whether an individual clinician or group is reporting.

If reporting as a group, does a quality measure for one specialty qualify as one of the six qualify measures for the entire group?


Is the 5% Advanced APM bonus subject to budget neutrality requirements?

No.  All Advanced APMs will receive the 5% bonus.

Is it possible to satisfy the quality measure reporting requirement through claims-based measures alone?

It is possible to select six measures that are reported through Part B claims, as there are several proposed measures that will be submitted through claims.  However, the Part B claims submission mechanism for quality measure reporting is available only to individual MIPS-eligible clinicians.  To meet the data completeness requirement, these clinicians would need to report at least six measures including one cross-cutting measure for 80% of their patients.  The Part B claims submission option is not available for groups.

Are there any provisions that address the Advancing Care Information requirement for physicians that will be changing their EHRs in 2017?

No. There are no such provisions in this proposed rule.

For Track 1 ACOs, will the composite performance score (CPS) be calculated at the ACO level or the individual practice level?

Under the proposed rule, a Track 1 ACO would be considered a MIPS APM.  For these APMs, CMS is proposing to generate a single MIPS CPS by averaging all scores for MIPS-eligible clinicians in the Track 1 ACO.

Is the APM bonus payment excluded from Medicare Shared Savings Program calculation? Does this exclusion also apply to MIPS bonus payment?

The APM bonus payment is excluded from the Medicare Shared Savings Program calculation.  Regarding MIPS, there is no bonus payment, as MIPS is an update to fee-for-service payments.

Is there a cap on the number of resource use points that a group can earn in MIPS?

Unlike the other performance categories, the resource use category is not based on points.  Rather, CMS will determine an average dollar value that can be attributed.

What is the cohort for measuring resource use, national, regional, or other?

Under the proposed rule, CMS states resource use measures “would be adjusted for geographic payment rate adjustments and beneficiary risk factors.”