QPP 2018 Deadline Checklist
It’s no secret that new payment programs can often seem daunting – especially in their first year – and the Quality Payment Program (QPP) is no exception.
Born out of the QPP are two participation tracks: the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (APM).
With a submission deadline of March 31, 2018, eligible clinicians (ECs) across the country are probably asking themselves if they dotted the i’s, crossed the t’s and checked all the right boxes.
While the Centers for Medicare & Medicaid Services (CMS) offer greater flexibility for the 2017 QPP reporting period, suffice to say, ECs are hoping for more than the bare minimum reimbursement. Fortunately for you, we created a handy checklist that will help guide you through the 2017 QPP submission process – check out the cliff notes below!
STEP 1: DETERMINE YOUR TRACK
Were you in an Advanced APM during the 2017 reporting year? Did you meet the minimum payment and patient requirement through your Advanced APM? If no, submit towards MIPS!
STEP 2: DETERMINE MIPS ELIGIBILITY & PARTICIPATION STATUS
Do you meet any MIPS Exclusion Criteria? Do you meet any MIPS Special Status Requirements? Are you participating in a MIPS APM (ex: ACO Track 1)? If you said yes to any of those questions, you are likely eligible for special exclusions and requirements.
STEP 3: DETERMINE IF PARTICIPATING AS A GROUP OR INDIVIDUAL
Are you using the same tax identification number (TIN) to report for 2 or more ECs? If no, submit your data as an individual.
STEP 4: PICK YOUR PACE
Did you report for a full year of data for all three performance categories? Choose the full year reporting option. Or, maybe you didn’t quite report for a full year, but did you report for at least 90 consecutive days for all three performance categories? Choose the partial year reporting option. If neither of those apply to you, submit the minimal amount of data under the test option to avoid a negative payment adjustment.
STEP 5: CHOOSE YOUR SUBMISSION MECHANISM
How are you sending your data to CMS? Via the CMS QPP Portal, Administrative Claims, Qualified Registry, Qualified Clinical Data Registry (QCDR), CMS Web Interface or Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey? Needless to say, you have quite a few options.
STEP 6: SELECT YOUR MEASURES AND ACTIVITIES
There are a number of measures you need to meet to be eligible for a positive reimbursement. When submitting for MIPS, ask yourself: “Did I select six Quality Measures? At a minimum, did I meet the Advancing Care Information (ACI) base score measures required for my Certified Electronic Health Record Technology (CEHRT)? Did I complete two high-weighted OR four medium-weighted OR one high-weighted and two medium-weighted Improvement Activities?” If you found yourself saying yes to each of those, odds are you will receive a positive reimbursement!
STEP 7: RECORD, REPORT, & SUBMIT DATA
With the option of so many submission mechanisms, it can get confusing quickly. It is important to note, if you are using the CMS portal to attest there are several steps that must be done before you are able to submit your data!