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  • MIPS 2023—Quality: Meet the Data Submission Thresholds

    This content is excerpted from EyeNet’s MIPS 2023: 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. (Note: The case minimum for administrative claims–based measures tends to be much higher. For example, measure 479: Hospital-Wide, All-Cause Unplanned Readmission 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 2023 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 1: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%). 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; for any other collection type, include both Medicare and non-Medicare patients. (Where can you find the denominator criteria for quality measures? CMS has said that it will upload the measure specifications at in early 2023. These hadn't been posted as of Jan. 23. Make sure you select performance year 2023 and are filtering the search results for the appropriate collection type.) 

    What if you don’t meet the case minimum requirement for a reported measure? If you are in a large practice, you score 0 points. If you are in a small practice, and you meet the 70%–data completeness criteria, your score would depend on how new the measure is: 7 points if this is its first year in MIPS; 5 points if this is its second year in MIPS; and 3 points for older measures.

    What if you don’t satisfy the data completeness criteria for a reported measure? If you are in a large prac­tice, you score no points; if in a small practice, you score 3 achievement points provided that you report on 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.

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

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