The third year of the MACRA Quality Payment Program (QPP) has begun and Kareo is here to help. We’ve created the Quality Payment Program (QPP) 2019 MIPS Action Plan to provide you with the necessary information, and steps to get you from preparation to data submission. Let’s get started:
Check your MIPS participation status by entering your individual NPI at https://qpp.cms.gov/participation-lookup. However, you may confirm yourself by answering the following questions:
- Do you have $90K or more in Medicare Part B allowed charges?
- Do you have over 200 Medicare Part B patients?
- Do you provide more than 200 covered professional services to Medicare Part B beneficiaries?
If you answered yes to all of the questions, and you are one of the clinician types listed here, you may be subject to MIPS. If you are subject to MIPS, you could be eligible for an exemption. Find out more here.
Achieving the requirements for MIPS 2019 takes the cooperation of the entire practice, so enlist the help of the key staff members who can meet at least biweekly to check your progress and make the necessary workflow adjustments to increase your performance. The ideal team should include the eligible clinician(s), office manager, and clinical assistant. It is important to discuss roles and responsibilities, and expectations must be established.
Educate yourself and your team. Establish recurring weekly or bi-weekly meetings to learn as a team about the QPP options, requirements and important deadlines. A few key responsibilities must be assigned:
- Designate the team member who will be responsible for running the Promoting Interoperability (PI) and Quality Reports
- Decide who will be responsible for staying informed and gathering details on any upcoming webinars, newsletters, blogs, announcements sent by Kareo, or updates from CMS. This staff member should share this information in your next team meeting
- Review and select your measures for Quality, Promoting Interoperability (PI), and Improvement Activities (IA)
- Discuss and establish your performance goals
- Determine your reporting period: 90 days or up to a full year for PI and IA (Quality must be reported for a full year)
Let the following checklist serve as a reminder of the tasks that must be completed to help you be better prepared for MIPS 2019.
- Confirm clinician eligibility and determine their QPP track: MIPS, APM or both
- Create a MIPS 2019 Audit Binder
- Participate in a training for MIPS 2019
- Select up to six quality measures, including one marked outcome or high-priority measure
- Select a registry such as Covisint to submit Quality measures on your behalf, or start submitting Quality measures via claims early in the year
- Go to https://qpp.cms.gov/mips/improvement-activities and select 2-4 Improvement Activities. Then save your supporting documentation in your audit binder
- Perform a Security Risk Analysis, or do a reevaluation of your existing security risk analysis
- Setup the Patient Portal
- Setup ePrescribing for your clinicians
- Register with your state to begin the process for Immunization Registry Submission (if applicable), then open a support case with Kareo
- Register with UpDox for Direct Messaging (required to Send/Receive and Incorporate summaries of care). A clinician should register first
- Enroll with eLabs. Or, create lab/studies orders in the patient’s charts when ordered by paper. Then manually add patient results
- Create a HARP account to submit your attestation here.
- Submit your data to CMS during the submission period Jan 1 to March 31, 2020
Now that you have confirmed your eligibility for MIPS 2019 and reviewed the checklist, it is time to get started! Start with creating your audit binder. It is best to keep a hardcopy as well as an electronic version of this folder. Your binder should include:
- Copies of your Quality and PI reports
- Any documentation to support any Improvement Activities selected
- A copy of your Security Risk Analysis (this one of the most important items you must keep in your binder)
- Any screenshots you took within Kareo EHR-Clinical to support any given objective
Next, refine the teams’ knowledge on MIPS 2019. The following websites are your best resources:
Determine your submission method as well as your reporting period for PI and IA. Quality must be reported for the full 2019 calendar year. At this point, you are ready to make your measure selections for each category. Things to keep in mind:
- Submission Method for Quality: QCDR, Registry, Claims (only for quality)
- Your reporting period and submission method for PI and Improvement Activities
- If your submission method is via registry, you must select measures that are supported by Kareo Clinical AND the selected registry
- If your submission method for Quality is claims, you may select from the measures listed on the QPP website.
This might also be a good time to review the MIPS Quality and PI Dashboard guides found at https://helpme.kareo.com/CMS_Incentive_Programs.
Select up to six measures, including at least one Outcome Measure or one High Priority Measure. Kareo provides built-in guides for each selected measure directly from the dashboards. Each team member should carefully read and understand the steps required to achieve a good score on each measure.
A clinician’s goal for the PI category is to reach the target score of 100 points. The target score can be achieved based on your performance in each measure. The name of each measure is a link that opens its guide.
Clinicians are rewarded for care focused on care coordination, beneficiary engagement, and patient safety. Eligible clinicians may submit their improvement activities by attestation via the CMS Quality Payment Program website, a qualified clinical data registry, a qualified registry, or when possible, from their electronic health record (EHR) system. Please note, currently, Kareo does NOT submit data directly to CMS on your behalf. There are two kinds of activities: high-weighted and medium-weighted activities. To achieve the maximum score of 40 points (20 points for small practices), a MIPS eligible clinician may select either of these combinations:
- High-weighted activities
- Medium-weighted activities
The list of Improvement Activities can be found at https://qpp.cms.gov/mips/improvement-activities. Eligible clinicians are encouraged to retain documentation for six years as required by the CMS document retention policy. Keeping this documentation in your MIPS 2019 audit binder will give you peace of mind should you be selected for an audit. Remember, you can most likely not run a report to prove you met a selected Improvement Activity.
Starting in 2019, the Cost category has a weight of 15% of the overall MIPS score. This category does not require any additional data submission from the eligible clinician. CMS will automatically calculate the clinician’s score based on Medicare Part B claims submitted. For more information about the MIPS Cost category, visit https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html.
Monitor Your Progress
Your team should review reports in your recurring MIPS meetings. This is the time to celebrate your year-to-date achievements and the best time to define or modify your action plan and work on improving measures that do not have an ideal score. Ask the following questions during your team meetings:
- How can we improve the score on measure XYZ?
- Should the team member responsible for the documentation of any given measure revisit the guide to ensure they are not accidently omitting a crucial step?
- Are there any other workflow adjustments the team can make to help improve the overall score?
It is important that reports are run and reviewed REGULARLY and that all items on Your MIPS 2019 Checklist are completed prior to your attestation period. Some of these items can significantly impact your scores.
Attestation Submission Period
Finally, prepare for your attestation and submission of data. The attestation submission period for the 2019 Reporting Year is January 1st to March 31st, 2020. It is crucial that you:
- Run your final Quality report for the full 2019 calendar year-- unless you reported quality via claims.
- Run your final PI report for the 2019 reporting period of your choice
- Gather the supporting documentation for your Improvement Activities
- Select and reach out to your submission registry. Reach out to us for the Kareo discount code if you select Covisint as your registry
- Place copies of your reports in your MIPS 2019 audit binder. Keep for a minimum of 6 years
- Submit your MIPS 2019 data to CMS by March 31, 2020
Congratulations, you did it!