MIPS Submission Season is Over… What Did We Learn?

May 2nd, 2019 by

Wow, here we are, already in early May and with two MIPS submission seasons behind us!  Here in the Midwest, Mother Nature is confused.  On Monday, it was 71 degrees and starting to really feel like Spring.  With the flower buds beginning to peek out, everyone was feeling happy and refreshed… until we woke up the next day to an icy layer of snow on the ground.  Reflecting back on MIPS submissions this year, our weather has been very symbolic of the ups and downs we experienced over the past few months.

We support over 60 healthcare organizations with their MIPS and MU submissions.  Being our second year of MIPS submissions, we knew what to expect based on 2017, and we were able to plan and prepare quite a bit going into this year’s submission season.  By early February, we felt very confident that all our customers would be submitted well in advance of the April 2nd deadline.

However, we ran into quite a few bumps along the way, mostly related to data validity.  Several different times we had to resubmit data based on updates to measure calculations.  CMS also made some benchmark adjustments late in the game that also changed measure recommendations for some Quality submissions.

By the end of submission season, we had submitted for almost 10,000 clinicians in 2018. The average score was 94% for all three categories that we submitted.  This is roughly the same as what we saw in 2017, which is great news as the program continues to get harder year by year.  I’ll share a few insights and learnings about submission this year compared to 2017 below. 

We have noticed some trends in 2018 across our customer base.  With one submission season under our belts, we are now seeing organizations become more focused.  Everyone is honing in on those measures that are relevant for their clinicians and really focusing on specific measure sets.  This is notably different from 2017, where the process was a bit more chaotic, and many were submitting just to avoid a penalty.  We discussed some of these insights in our recent ABC’s of the QPP webinar:

Watch the full replay.


Another opportunity to boost scores in 2018 was by submitting individual clinicians that had stronger performance than the TIN, while also submitting as part of the group.  Because CMS takes the higher of the two scores, the individual clinician inherits a higher overall MIPS score and payment adjustment.  An added bonus is that the clinicians will inherit individual cost performance so that organizations will have insights at the individual level as well as the group.

Looking forward to 2019, the program gets even harder.  Promoting Interoperability (PI) has significant changes in measures and how the category is calculated.  The Quality benchmarks continue to rise, and cost continues to increase in significance.  The Performance Threshold is raised to 30 points, so it won’t be as easy to avoid a negative payment adjustment as in years past.  We will all be held at the expense of any last-minute changes, such as EHR readiness, measure data validation, late benchmark updates, etc.  If there are any reasons beyond your control that will not allow you to submit PI or Quality, it will be very difficult to avoid a negative adjustment with your Improvement Activities and Cost scores alone.

Overall, this submission year was exciting, and with everything we’ve learned, we’re even better prepared for 2019.  It’s getting somewhat easier for organizations to build strategies around MIPS performance and execute earlier in the year.  Now almost mid-way through 2019, organizations are starting to feel more stable around the MIPS program, just as the temperatures are getting more consistent for us in the Midwest. Now that we’re through the submission season, we’re looking forward to taking on 2019 MIPS!

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