CMS releases key 2017 Medicare QPP benchmark information

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The American Medical Association (AMA) reports that the Centers for Medicare & Medicaid Services (CMS) has posted key information on the Medicare Merit-Based Payment System (MIPS) on its Quality Payment Program (QPP) website.

AMA says that, “If a physician or practice plans to participate in the 2017 [QPP/MIPS program] with the goal of receiving a bonus in 2019, it is highly recommended that they review the recently released 2017 QPP measure benchmark information…[this] information does not apply to physicians who only plan to participate in 2017 to avoid a 2019 penalty (submit one measure, one time in 2017).”

AMA explains that, “The benchmark calculations for the 2017 performance year use data that was submitted for PQRS in 2015 by clinicians that were a QPP provider type eligible for MIPS and were not newly enrolled in 2015, or groups with at least one such clinician. When a clinician submits measures for the QPP Quality Performance Category, each measure is assessed against its benchmarks to determine how many points the measure earns. A clinician can receive anywhere from three to 10 points for each measure (not including any bonus points). Benchmarks are specific to the type of submission mechanism: EHRs, QCDRs/Registries, CAHPS and claims. For CG-CAHPS, the benchmarks are based on two sets of data, 2015 PQRS CAHPS and 2015 ACO CAHPS data. Submissions via CMS Web Interface will use benchmarks from the Shared Savings Programs.”

AMA adds that, “Each benchmark is presented in terms of deciles. Points will be awarded within each decile (see Table 1). Clinicians who receive a score in the first or second decile will receive three points. Clinicians who are in the 3rd decile will receive somewhere between 3.0 and 3.9 points depending on their exact position in the decile, and clinicians in higher deciles will receive a corresponding number of points. For example, if a clinician submits data showing 83 percent on the measure, and the 5th decile begins at 72 percent and the 6th decile begins at 85 percent, then the clinician will receive between 5.0 and 5.9 points because 83 percent is in the 5th decile. For measures where a positive performance is seen in a lower score, the scores are reversed in the benchmark deciles.”

AMA also notes that CMS has posted the list of patient-facing encounter codes on the QPP website. This list is “used to determine the non-patient facing status of MIPS eligible clinicians. Given the flexibility in program requirements for non-patient facing clinicians, the encounter codes are critical for CMS to identify MIPS eligible clinicians.”

According to AMA, a non-patient facing MIPS eligible clinician is…

– An individual MIPS eligible clinician who bills 100 or fewer patient-facing encounters (including Medicare telehealth services defined in section 1834(m) of the Act) during the non-patient facing determination period and

– A group provided that more than 75 percent of the clinicians billing under the group’s TIN meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period

Finally, AMA says that, “The list of patient-facing encounter codes are categorized into three overarching groups of codes (Evaluation and Management Codes; Surgical and Procedural Codes, and Visit Codes). The utilization of Evaluation and Management Codes, Surgical and Procedural Codes, and Visit Codes classifies MIPS eligible clinicians as non-patient facing and patient-facing.”

Click for CMS QPP website