Excerpted from MIPS—What’s New in 2020 for Ophthalmology (EyeNet, January 2020). Also see MIPS 2020: A Primer and Reference, which is being posted online ahead of print.
Update: On Dec. 31, 2019, CMS published the benchmark data for 2020 quality measures and confirmed that measures 1 and 236 would have flat benchmarks.
The data completeness criteria is now 70%. When you report a quality measure, you should report on at least 70% of denominator-eligible patients (up from 60% in 2019). What if you report on fewer than 70%? If you are in a small practice, and you report on at least one patient, you will score 3 achievement points for that measure; if you are in a large practice, you would score 0 achievement points (down from 1 achievement point in 2019).
CMS may introduce “flat benchmarks” for two measures. CMS is reviewing the performance data for measure 1: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9) and measure 236: Controlling High Blood Pressure. The agency is concerned that standard benchmarks may motivate clinicians to reduce blood sugar or blood pressure to a level that might be too low for patients with certain medical conditions, and it may address that by applying a new type of benchmark— the flat benchmark.
What is a flat benchmark? A flat benchmark is not based on performance data. Instead, it is based on a simple formula: A performance rate of at least 90% earns you 10 achievement points, a performance rate of 80%-89.9% earns you 9 achievement points, etc.
For inverse measures, such as measure 1, where a lower score represents better performance, CMS has said that a performance rate of 10% or less earns you 10 achievement points, a performance rate of 10.1%- 20% earns you 9 achievement points, etc.
For flat benchmarks, there would still be a floor of 3 achievement points for both small and large practices, provided they meet the 70%–data completeness criteria.
Example—measure 236: Controlling High Blood Pressure? For measure 236, your performance rate is based on the percentage of hypertensive adults (aged 18-85) whose blood pressure is adequately controlled (<140/90 mm Hg). You score up to 10 achievement points based on how that performance rate compares against one of three benchmarks.
How measure 236 is scored for 2019 performance. What did it take to score 10 achievement points in 2019? That depends on which benchmark applies: Your 2019 performance rate would need to be 100% if reporting manually through a registry; at least 94.89% if through claims; and at least 82.21% if using electronic end-to-end reporting, whether via your electronic health record (EHR) vendor or via IRIS Registry–EHR integration.
How measure 236 might be scored in 2020. At time of press, CMS hadn’t yet published measure 236’s three benchmarks for 2020. If any of those benchmarks require a performance rate of more than 90% to earn 10 achievement points, then CMS will convert that benchmark into a flat benchmark.
When does CMS announce the 2020 benchmarks? CMS had said that it would publish the 2020 benchmarks for quality measures in late December 2019. (Note: Benchmarks are typically based on performance data from previous years: For 2019, benchmarks are generally based on performance data from 2017; for 2020, benchmarks will mainly be based on performance data from 2018.)
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