MIPS: Cost Category, Feedback Reports and Targeted Reviews

In the Cost category under the Merit-based Incentive Payment System (MIPS), practices do not need to submit data as the Centers for Medicare & Medicaid Services (CMS) relies on using administrative claims data. If your practice met the case minimum for at least one Cost measure (see the requirements here), you can access any feedback reports from the Quality Payment Program portal.

The Cost category feedback reports are generated from claims data reviewed from the previous performance year. The reports are released anywhere from six to eight months after the end of the calendar year. If a practice wants to ensure that they are on track with containing costs, they need to review the reports without delay in order to take action and make improvements within the practice.

Practices will need a HARP (HCQIS Access Roles & Profile) account to log into the Quality Payment Program (QPP) portal. HARP was previously known as an EIDM (Enterprise Identity Management) account. See how to create and access your HARP account here.

Feedback Reports will take you to a dashboard that will show your overall performance score with the MIPS payment adjustment as well as the payment adjustment date.

As you click on the link – like the Cost category – you will see information pertaining to your score, the performance period date (the time period reviewed to get your Cost performance score) and the number of measures you were scored on. You only receive Cost feedback on measures that you meet the case minimum on. For example, if you only have feedback for Total Per Capita Cost (TPCC), this tells you that you did not meet the case minimum for Medicare Spending Per Beneficiary (MSPB).

Using the TPCC measure as an example, you will be able to investigate further to see the actual average cost of attributed beneficiaries and download beneficiary level data to see what impacted your score (patient age, diagnosis of diabetes/CAD/COPD/heart failure, E&M services billed, procedures billed, etc.). Scoring for Cost measures is based on the national average for all physicians, not just the physicians in your specialty, but CMS does make adjustments for regional differences, specialty differences, and patient risk scoring.

Practices and clinicians must remember that if they do not meet the case minimum in either of the Cost measures, they will not receive Cost feedback reports. And if no Cost data was scored, the Cost category will reweight to the Quality category.

Targeted Reviews

If your practice reviews its 2018 MIPS Performance Review Feedback and 2020 MIPS payment factor adjustment (see HARP Account) and feels that an error was made, you can request a Targeted Review. The Targeted Review can be requested through Sept. 30, 2019, at 8 p.m. EDT, but CMS recommends submitting the request as soon as possible to avoid any delays or technical issues that may push you beyond the deadline.

Reviews can be requested for errors on CMS’ review of your data submission, but not on the methodologies CMS uses to establish the standards or thresholds.

You can request a Targeted Review by completing the form on the QPP website. Ensure you have gathered your data and files (encrypted to protect patient information) as CMS will generally request supporting documentation within 30 days.

Once you receive a Targeted Review Outcome, the decisions are final and there will be no further review.

The Quality Reporting Engagement Group can work with practices on their feedback reports and suggest potential “course corrections” to help better the practices performance in the category.

If you have questions about the Cost category and how your claims data is reviewed, or any other category of your MIPS performance process, contact internal_sales_associate@intrinsiq.com.

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