CMS Issues MIPS Eligible Measure Applicability Resources
October 2017 ~
Designed to reward physicians for providing better care, the Medicare Access and CHIP Re-authorization Act of 2015 (MACRA) combines several programs into a single system. Physicians are able to practice as they always have, but will earn higher Medicare payments based on performance and participation in important activities.
Under the new MIPS, six measures are required, including one outcome or high priority measure, with each earning up to 10 possible points. Each measure is scored individually and then added together and weighted for the final MIPS score. Providers get points for the measures submitted, but not for measures which were not submitted.
Eligible Measure Applicability (EMA) Process
Under the Quality performance category, providers who report quality data via claims or a qualified registry and report less than the required quality six measures for a program year, CMS will use Eligibility Measure Applicability (EMA) to determine whether or not additional measures applied and should have been reported.
CMS will use the EMA process to see if there are clinically related measures that could have submitted if:
- Quality data through claims or a qualified registry, and
- Less than the required quality measures for a program year.
For 2017, there are 274 quality measures available. For full participation in 2017, physicians expected to:
- Submit six quality measures; one of them is required to be an outcome measure, if available. If an outcome measure is not available, then physicians must submit a high priority measure. Physicians and/or groups would also have to meet the data completeness requirement (50% or more of denominator eligible encounters) for each measure submitted; or
- Submit a complete specialty measure set. All of the measures in a specialty set will be assessed when less than 50% of denominator eligible instances are submitted.
If a physician or group submits data on less than six measures, the EMA process:
- Uses a clinical relations test to see whether or not physicians could have submitted more measures, including outcome and high priority measures.
- Adjusts the scoring to accurately reflect how the clinical relations test affected individual or group performance.
Similar to the PQRS Measure Applicability Validation process, EMA includes two steps:
- Clinical Relation Test
Based on the one to five measures submitted, CMS will search for other clinically related quality measures that could have been submitted. This same criteria is applied if none of the measures submitted was an outcome or high priority measure. Based on the measures submitted, CMS will search for clinically related outcome or high priority quality measures that could have been submitted.
- Minimum Threshold Test
If any measures were found in step one, CMS will analyze Medicare claims submitted during the reporting period to see if the provider had at least 20 denominator eligible instances.
The EMA process will only be used with claims or qualified registry data submissions. EMA does not impact any other aspect of scoring, including case minimums which are necessary for earning beyond the minimum three points per measures just for submitting any data at all. If additional measures are found and at least 20 eligible instances are identified, the provider’s score will continue to be based on a total of six measures and 60 points possible. If additional measures are not found, or if the ones that are found do not pass the minimum threshold test, then the score will be based on the total number of measures reported multiplied by 10 points each.
To help physicians and groups prepare for successful participation in the EMA process, CMS released the following resources:
- MIPS Quality Performance Category EMA Fact Sheet
- 2017 EMA for Claims Data Submission of Individual Quality Measures
- 2017 EMA for Registry Data Submission of Individual Quality Measures
- MIPS Overview webpage
- Quality Measures webpage