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  • MIPS 2022—Quality: Meet the Data Submission Thresholds

    This content is excerpted from EyeNet’s MIPS 2022: A Primer and Reference; 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. 

    The case minimum: Report on at least 20 patients. You will actively report six or more quality measures. For these measures, the case minimum is 20—though CMS now has the authority to introduce new measures that might have a case minimum other than 20. For example, CMS introduced a new measure for primary care physicians that has a case minimum of 30. (Note: The case minimum for administrative claims–based measures tends to be much higher. For example, measure 479: Hospital-Wide, All-Cause Unplanned Readmission (HWR) Rate for the MIPS Eligible Clinician Groups has a case minimum of 200.)

    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 2022 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. (Where can you find the denom­inator criteria for quality measures? If you are reporting via the IRIS Registry, you can find that information in your dashboard. If reporting via claims, you can download the specifications for claims-based measures at

    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? If in a large practice, you earn no points; if in as small pracitce, you score 3 achievement points provided that you report at least one patient. (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. 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 address this when it states 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’d be failed for cherry picking.

    Previous: Quality: Reporting Quality Measures

    Next: Quality: Manual Reporters Via the IRIS Registry Will Need Their Data-Completeness Totals 

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