• MIPS 2020—Quality: Meet the Data Submission Thresholds

    This content is excerpted from EyeNet’s MIPS 2020; also see the Academy’s MIPS hub page.


    When you report a measure, you must meet both the case mini­mum requirement and the data completeness criteria in order to earn achievement points based on your performance rate and, for a high priority measure, earn high-priority bonus points.

    The case minimum requirement is 20 patients. The ex­ception is the all-cause hospital readmission (ACR) measure, which has a 200-patient case minimum.

    The data completeness criteria—report on at least 70% of denominator-eligible patients. For each measure that you report, submit data on at least 70% of denominator-eligible patients who were seen during the entire 2020 calendar year.

    Who are the denominator-eligible patients? That de­pends on the quality measure as well as on what collection type you are using to report that measure. Suppose, for ex­ample, you are reporting measure 117: Diabetes: Eye Exam. The denominator-eligible patients for that measure would be those with diabetes who are 18-75 years old. If you are reporting via the Medicare Part B claims collection type, you would just include Medicare patients; if you are using any other reporting mechanism, you would include both Medi­care and non-Medicare patients. Your reporting will indicate what percentage of those patients had an eye screening for diabetic retinal disease. (To see the denominator criteria for quality measures, go to the detailed listings at aao.org/medicare/quality-reporting-measures.)

    What if you don’t meet the case minimum requirement for a reported measure? You will score 3 achievement points for it, provided you satisfy the data completeness criteria.

    What if you don’t satisfy the data completeness criteria for a reported measure? Provided that you report at least one patient, you will score 3 achievement points if you are in a small practice; 0 achievement points (down from 1 point in 2019) if you are in a large practice. (To learn how CMS assigns practice size, see “Small or Large Practice?”)

    Do Not Cherry-Pick Your Patients

    If you report on fewer than 100% of patients, do not cherry-pick. When you submit your MIPS quality data to CMS, you must certify that, to the best of your knowledge, your data are “true, accurate, and complete.” Last August, CMS clarified that if you report on a measure for fewer than 100% of applicable patients, you must not cherry-pick patients with the goal of boosting your performance rate. The MIPS regulations for 2020 underscore that, stating that if “quality data are submitted selectively such that the submitted data are unrepresentative of a MIPS eligible clinician or group’s performance, any such data would not be true, accurate, or complete.” In an audit, you would be failed for cherry picking.

    Previous: Quality: Reporting Quality Measures

    Next: Quality: Who Reports Data Completeness Totals?

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