Fall 2021 Newsletter

If you have not already captured the required Merit-based Incentive Payment System (MIPS) data for performance year 2021, please note that the final continuous 90-day performance period will begin on October 3, 2021. The Improvement Activities and Promoting Interoperability categories require you to report data specific to at least one continuous 90-day period (unless otherwise stated).

Complete and accurate submission of data is critical because MIPS-eligible clinicians will receive a positive, negative or neutral adjustment in the 2023 payment year based on 2021 MIPS final scores. MIPS performance categories include:

• Quality
• Cost
• Improvement Activities
• Promoting Interoperability

You will report the required performance category data during the 2021 submission period (January 3, 2022 – March 31, 2022).

MIPS Reporting Exceptions

There are two exception applications currently available through the Quality Payment Program (QPP):

• Extreme and Uncontrollable Circumstances Exception: Request reweighting of any or all performance categories if extreme and uncontrollable circumstances interfere with the ability to report data (e.g., COVID-19 public health emergency).
• MIPS Promoting Interoperability Performance Category Hardship Exception: Hardship exceptions are available for the following specified reasons:
  • You’re a small practice
  • You have decertified EHR technology*
  • You have insufficient internet connectivity
  • You face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues
  • You lack control over the availability of CEHRT

*Simply lacking the required CEHRT doesn’t qualify for reweighting.

Exception applications and additional information are available through the QPP website: https://qpp.cms.gov/mips/exception-applications. Applications can be submitted through December 31, 2021.

Next Steps for Reporting

Additional MIPS Resources:

2021 MIPS Quick Start Guide: https://qpp.cms.gov/resources/resource-library (search for “quick start”)

QPP Participation Status Lookup Tool: https://qpp.cms.gov/participation-lookup

As green leaves turn red and the warm summer winds turn brisk, we are reminded that the end of the year is almost upon us. We humbly ask that you engage with your Quality Nurses and outreach to your patients to close their care opportunities.

Please continue to perform Annual Wellness Visits for your patients, adopt PHQ9s for Depression Screening and create follow-up plans for behavioral health issues.

United is a priority over the next month as our current measurement period concludes at the end of September 2021. Please engage with your Quality Nurses to help close outstanding care opportunities, including:

• Well-Child Visits in the 0-15 Months of Life
• Well-Child Visits in the 15-30 Months of Life
• Childhood Immunization Status: Combo 2 (2 years)
• Child and Adolescent Well-Care Visits
• Chlamydia Screening in Women (16-24 years)
• Breast Cancer Screening (50-74 years)
• Cervical Cancer Screening (21-64 years)
• Comprehensive Diabetes Care: HbA1c Test (18-75 years)
• Comprehensive Diabetes Care – Eye Exam (18-75 years)
• Colorectal Cancer Screening (50-75 years)

We also ask that our providers continue to outreach to Blue Shield and, contract permitting, Anthem patients for the following care opportunities:

• Breast Cancer Screening
• Diabetes HA1C Testing
• Well-Child Visits 3-6 years old
• Diabetes Proteinuria Screening
• Chlamydia Screening
• Cervical Cancer Screening

As the weather changes, please remember the following protocols as seasonal ailments begin to rise.

• Appropriate Treatment for Children with Upper Respiratory Infection (URI): Most URIs are caused by viruses that require no antibiotic treatment. Too often antibiotics are prescribed inappropriately. The misuse of antibiotics can have adverse clinical outcomes such as Clostridioides difficile infections and has public health implications, including encouragement of antibiotic resistance (when antibiotics can no longer cure bacterial infections). Antibiotic resistance is a major health concern in the U.S. Members 3 months of age and older with a diagnosis of (URI should not immediately result in an antibiotic dispensing event. Providers should dispense prescription for an antibiotic medication on or three days after the Episode Date. (from NCQA)
• Appropriate Treatment for Adults with Acute Bronchitis: Acute bronchitis/bronchiolitis almost always gets better on its own; therefore, individuals without other health problems should not be prescribed an antibiotic. Ensuring the appropriate use of antibiotics for individuals with acute bronchitis/bronchiolitis will help them avoid harmful side effects and possible resistance to antibiotics over time. Antibiotic resistance is a major health concern in the U.S. Members ages 3 months and older with a diagnosis of acute bronchitis/bronchiolitis should not immediately result in an antibiotic dispensing event. (from NCQA)
• Appropriate Testing for Children with Pharyngitis: Pharyngitis is a leading cause of outpatient care and can be caused by a viral or bacterial infection. Viral pharyngitis does not require antibiotic treatment, but antibiotics continue to be inappropriately prescribed. Proper testing and treatment of pharyngitis prevents the spread of sickness, while reducing unnecessary use of antibiotics. The misuse of antibiotics can have adverse clinical outcomes such as Clostridioides difficile infections and has public health implications including encouragement of antibiotic resistance (when antibiotics can no longer cure bacterial infections). Antibiotic resistance is a major health concern in the U.S. Members 3 years and older where the member was diagnosed with pharyngitis and dispensed an antibiotic should receive a group A streptococcus (strep) test for the episode. (from NCQA)

And please continue to remember the following protocols throughout the year:

• Use of Imaging Studies for Low Back Pain: Evidence shows that unnecessary or routine imaging (X-ray, MRI, CT scans) for low back pain is not associated with improved outcomes. It also exposes patients to unnecessary harms such as radiation and further unnecessary treatment. For the majority of individuals who experience severe low back pain, pain improves within the first two weeks of onset. Avoiding imaging for patients when there is no indication of an underlying condition can prevent unnecessary harm and unintended consequences to patients and can reduce health care costs. Members with a primary diagnosis of uncomplicated low back pain should not have an imaging study (plain X-ray, MRI, CT scan) within 28 days of the diagnosis. (from NCQA)
• Use of Opioids at High Dosage: Opioid-related overdoses account for tens of thousands of deaths per year in the U.S. Of those, 40% involve prescription opioids. Literature suggests there is a correlation between high dosages of prescription opioids and the risk of both fatal and nonfatal overdose. The Centers for Disease Control and Prevention (CDC) guideline on opioid prescribing for chronic, nonmalignant pain recommends the use of “additional precautions” when prescribing dosages ≥50 mg morphine equivalent dose (MED) and recommends providers avoid or “carefully justify” increasing dosages ≥90 mg MED. (from NCQA)
• Concurrent Use of Opioids and Benzodiazepines: Likewise, the CDC has issued guidelines for the prescribing of opioids. They recommend that clinicians avoid prescribing benzodiazepines concurrently with opioids whenever possible. Both prescription opioids and benzodiazepines now carry FDA “black box” warnings on the label highlighting the dangers of using these drugs together. (from the NIH)

We feel blessed to have providers who prioritize patient care and are grateful for our partnership. If you have any questions, please feel free to contact our CIN Director of Quality, Christian Kim, at [email protected].

CMS finalized MIPS Value Pathways (MVPs) as part of the 2020 Medicare Physician Fee Schedule Final Rule, and this participation framework was set to begin during the 2021 performance period. However, implementation was delayed due to stakeholder feedback.

CMS has proposed introducing MVPs as a reporting option for the 2023 performance year with a long-term vision to potentially sunset traditional MIPS at the end of the 2027 performance year and data submission period. Seven MVPs have been proposed:

• Rheumatology
• Stroke Care and Prevention
• Heart Disease
• Chronic Disease Management
• Emergency Medicine
• Lower Extremity Joint Repair
• Anesthesia

Each MVP includes associated measures and activities focused on patient-centered care, patient outcomes, population health, health equity, interoperability and reduced reporting burden for clinicians. CMS recognizes the need for additional MVPs development and plans to gradually implement more pathways relevant to specialties and subspecialties.

Comprehensive MVP program information, including a link to the proposed rule, is available through the QPP website: https://qpp.cms.gov/mips/mips-value-pathways. We recommend that each practice start to become familiar with this program as it will be a CMS reporting requirement in the near future.