Once again, Patient360 maintains continued, uninterrupted status as both a CMS Qualified Registry (QR) and a CMS Qualified Clinical Data Registry (QCDR.) Why is this status important for MIPS 2019 reporting and beyond, and what does it mean for you? Patient360 is ready for 2019 MIPS reporting, are you?
Quick history: In order to understand MIPS 2019, it’s important to know the entire QPP program is basically a “revision” of the legacy programs; i.e., PQRI/PQRS/Quality, Meaningful Use/ACI/PI, and Value Based Modifier (VBM)/Cost. While many insist it’s a totally different program, how it has evolved and what it actually “feels” like today… it is pretty much the same. Perform well on CMS specified quality measures (and other categories) or get penalized. And, if you perform really well, you might get a bonus (and as we all know in a budget neutral program after the first bonuses have been allocated, it’s not nearly as much incentive as anyone thought).
While in spirit, the concept is meant to improve quality of care, optimize patient outcomes, and save money, there really isn’t any empirical data illustrating this has ever happened. Not under the legacy programs nor after the revamping. It bears asking whether this deeply flawed program is making any difference? That said, it’s clear with the release of the Final Rule here in Year 3 that MIPS is here to stay.
So, sink or swim. If your TIN is eligible under MIPS, you need to get your data to CMS somehow. Let’s help you swim here by sharing with you one of the most common inquiries we receive from folks: What’s the easiest way to get my data to CMS??? CMS would like you to believe all the options they provide are “simple.” After you actually decipher the chart below:
(page 32 of this slideshow) and where/how your TIN fits into this chart, have fun trying to use direct upload into the QPP interface or attempting to use CMS web interface methods for your TINs submission. If you don’t have a FTE designated MIPS staff member to manage the endless policy changes and interpretations, and another FTE developer to move from policy to actual code, production, and submission, it’s an impossible task.
Enter the Qualified Registry (QR) and Qualified Clinical Data Registry (QCDR); i.e., the easiest solution for getting your data to CMS. But alas; all QRs and QCDRs are NOT alike! You want to make sure your QR or QCDR function optimally:
- One stop shop for ALL categories (Quality, PI, and IA) so you don’t have to attest and submit via separate user interfaces. Many QRs/QCDRs only submit on the quality category. Who feels like logging into more than one portal to get this done? It’s like ordering on Amazon and then being redirected to a product if it’s not “prime.” No thanks.
- Vetted by CMS to submit ALL Qualified Registry eligible measures. Don’t limit yourself by working with a Qualified Registry/QCDR that can only submit a very specialized set of measures. There will ALWAYS end up being universal Quality Measures that fall outside of a TINs specialty that are applicable. So, choose a Qualified Registry that can provide you with ALL measures which increases submission flexibility and opportunity for optimal performance.
- Uninterrupted Qualified Registry/ QCDR status: Beware of pop- up Registries! Know the long time players. Experience and historic success matters. Legacy program knowledge and participation is critical. Look for QRs or QCDRs that have legacy status under PQRI & PQRS. Find the ones that have successfully transitioned to MIPS as the program evolved. Don’t underestimate the value brought to the table by veteran registries vs. newbies. The tenured teams know the nuances of the program, have staff well versed in statute and facts, and help you make well informed decisions based on the span of a highly complex, 16 year program. If a Qualified Registry or QCDR has only come into existence with the start of MIPS, steer clear!
- No Probation by CMS: In order to keep the uninterrupted status as a Qualified Registry/QCDR, entities must annually undergo a rigorous self -nomination process including a detailed Data Validation Plan. Look for QRs/QCDRs that have successfully been doing this the longest with no interruption and no probation. Various entities are put on probation for not meeting the criteria of their Data Validation Plans. CMS has the power to place entities on probation for a performance period or for the following performance period. In other words, a probationary registry must submit a corrective action plan to remain authorized to submit data. CMS will automatically require a corrective action plan if a vendor has data inaccuracies including multiple TIN/NPI mismatches, formatting issues, calculation errors, or data audit discrepancies that affect more than 3% of that registry’s eligible clinicians or groups. In other words, 97% accuracy is expected and achievable by registries in the know. If an entity is on probation, it’s not a good sign.
Certainly P360 successfully demonstrates the above; but be well informed by reviewing the CMS Public Posting of all 2019 Qualified Registries / 2019 QCDRs, and make the best decision for your practice. Whatever you decide, getting started now on data submission for 2019 will put place you in good stead allowing you to make necessary changes in real time to improve your quality of care.
Additional information regarding previous Qualified Registries under the legacy PQRI and PQRS program can be found here as well: