February 13, 2018: CMS responds to MGMA concerns of MIPS vital information missing

Advocacy Letter - February 27, 2018

Quality Payment Program

DEPARTMENT OF HEALTH AND HUMAN SERVICES                                                                       
Centers for Medicare & Medicaid Services
7500 Security Boulevard, Mail Stop S3-02-01
Baltimore, Maryland 21244-1850

February 13, 2018

Mr. Anders M. Gilberg
1717 Pennsylvania Avenue NW #600
Washington, DC 20006

Dear Mr. Gilberg:

Thank you for contacting the Centers for Medicare & Medicaid Services (CMS) regarding the 12 months of quality data and the eligibility requirements for Performance Year 2 (2018) of the Quality Payment Program (QPP), specifically as it relates to the Merit-based Incentive Payment System (MIPS).

As you know, the QPP 2018 Final Rule requires 12-months of data for the Quality and Cost performance categories in Year 2. For the 2017 Transition Year, a 12-month reporting period for Quality was also encouraged, but given the participation flexibility through Pick Your Pace, clinicians had the option to report as little as one day of quality data to satisfy the minimum reporting requirements.

Requiring 12-months of quality data reporting moves us towards a more robust program in Year 3 (2019). We would also like to emphasize that in Year 2 (2018), the program is structured so that a clinician can still perform well in MIPS overall, if they put forth efforts in quality and the other performance categories and/or receive bonus points.

Regarding the eligibility requirements, for the 2017 Transition Year, we provided clinicians with basic MIPS eligibility information on the National Provider Identifier (NPI) look-up tool. We intend to make that information available even earlier this year and we're working to ensure that it is user-friendly and accurate. We anticipate making this information public in the first quarter of 2018.
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