• MIPS 2021—Quality: ICD-10 Turbulence and Changes in Clinical Guidelines

    This content is excerpted from EyeNet’s MIPS 2021; also see the Academy’s MIPS hub page.


    During the course of the year, a quality measure may be impacted by “significant changes” to its clinical guide­lines, to its measure specifications, or to relevant codes (e.g., updates or deletions of ICD-10, CPT, or HCPCS codes). This can mean that continued adherence to the measure’s original specifications—as defined at the start of the performance year—could result in “patient harm” and/or “misleading results” on performance quality. In such cases, CMS may truncate the performance period for that measure or suppress the measure altogether, de­pending on when in the year the changes take place.

    Truncation or suppression? If a quality measure has been impacted by a significant change, are there nine consecutive months of performance data that are unaf­fected by that change? If there are, then CMS will as­sess clinician performance for that measure based on a truncated nine-month performance period. If there aren’t, then CMS will suppress the measure altogether.

    Truncation example. Each year, on Oct. 1, CMS im­plements changes to the ICD-10 codes. These diagnosis codes are used to determine which patients are eligible for each quality measure. If the Oct. 1 changes to the ICD- 10 code set have significant repercussions for a measure’s performance rate, CMS can score you on that measure based on your performance from Jan. 1 to Sept. 30.

    What if a measure is suppressed? Clinicians aren’t scored on suppressed quality measures. If you submitted data on a quality measure before it was suppressed— because, for example, you reported it by claims—1) you wouldn’t score points for that measure, and 2) when CMS calculates your quality score it would reduce your de­nominator by 10 points (so you wouldn’t be penalized for reporting the suppressed measure).

    Which quality measures are affected? CMS will an­nounce on its website which measures are scored on a truncated performance period or suppressed altogether, and has said it will do so “as soon as technically feasible” but no later than Jan. 2, 2022.

    UPDATE. On June 30, 2021, CMS announced that it was suppressing two measures for claims-based reporters: Measure 1: Diabetes: Hemoglobin A1c Poor Control (>9%) and Measure 117: Diabetes: Eye Exam. The reason why? For the 2021 performance year, the specifications of those two measures had been updated: CPT codes were added to the algorithm that is used for determining whether or not a patient should be included in the numerator for these measures. However, CMS didn’t initially update its systems to reflect the changes to the measure specifications. Consequently, the performance rates for those two measures might not be accurate for claims-based reporters. The June 30 announcement only applies to those who are reporting MIPS via claims; it does not impact clinicians who are reporting MIPS via the IRIS Registry.

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    Next: Table: Reporting MIPS Quality Measures via IRIS Registry–EHR Integration 

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