MIPS 2020—Quality Scoring: Some Benchmarks Are Subject to Scoring Limitations

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

If your reporting for a measure meets the two data submission thresholds, your performance rate will be compared against a benchmark and you can earn achievement points depending on how your performance stacks up. For some benchmarks, the full range of 3-10 achievement points is available. However, some benchmarks are subject to scoring limitations. When you review the table(s) of quality measures for your chosen collection type(s), watch for benchmarks where scoring “stalls” or that are subject to a 7-point cap, and be mindful of measures that don’t yet have a benchmark:

• Table: Reporting MIPS Quality Measures Via IRIS Registry–EHR Integration
• Table: Reporting MIPS Quality Measures Manually via the IRIS Registry
• Table: Reporting Quality Measures Via Medicare Part B Claims

Scoring “stalls” for some benchmarks. Benchmarks for some measures approach maximum performance before the ninth decile. If, for example, you use the IRIS Registry to manually report measure 374: Closing the Referral Loop, the relevant benchmark reaches a 99.99% performance rate at the sixth decile (see Table, below). You can still earn 10 achievement points with a 100% performance rate, but with a less-than-perfect performance, scoring stalls at 6.9 achieve­ment points.

A 7-point cap for some benchmarks. Once a quality benchmark is in its second year of being “topped out” it becomes subject to a 7-point cap.

What is a topped out benchmark? CMS considers a benchmark to be topped out if there is limited opportunity for improvement. For example, a process-based measure would be considered topped out if the median performance rate was at least 95%. CMS is concerned that such benchmarks provide very little room for improvement for most of the MIPS eligi­ble clinicians who use those measures.

The end of the line for some topped out benchmarks. Once a benchmark is topped out for three consecutive performance years, CMS will consider eliminating it in the fourth year. Furthermore, if CMS finds that a benchmark is extremely topped out (e.g., average performance rate of a process-based measure is 98% or higher), it may eliminate it the following year.

What if there is no benchmark? If there wasn’t enough performance data from 2018 to establish a reliable bench­mark for a measure, or if the measure didn’t exist in 2018, CMS will try to establish a benchmark retroactively using 2020 performance data. However, CMS won’t assign a bench­mark to a measure unless at least 20 clinicians or groups submit performance data that meet the two data submission thresholds.

If CMS is unable to establish a benchmark for a measure, you won’t be able to earn more than 3 achievement points for reporting that measure.

Table: Scoring for Measure 374 “Stalls” When Reported Manually via the IRIS Registry

When you report measure 374: Closing the Referral Loop manually via the IRIS Registry, scoring for the benchmark stalls at decile 6. (Note: This measure does not stall when reported via IRIS Registry–EHR integration; it is not available for claims-based reporting.) 

Table: Examples of 7-Point Cap and Score Stalling

Measure 117: Diabetes Eye Exam. The three benchmarks for measure 117 demonstrate two types of scoring limitations for achievement points—a 7-point cap is imposed on two of them and scoring “stalls” for two of them.

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