Reporting Factors Overview

In the Quality Payment Program, there are certain factors, including Special Statuses, QPP Exceptions, Facility-based Determinations, MAQI and the Quality Measures Reporting Study, that can affect your reporting requirements for the different performance categories. These factors can result in fewer or no reporting requirements for a specific performance category.

Special Statuses

CMS retrieves and analyzes Medicare Part B claims data to determine who receives a special status. Those with a special status qualify for reduced reporting requirements in certain performance categories.  Special status applies to those who are practicing in a rural area or Health Professional Shortage Area (HPSA); non-patient facing, hospital-based, or ambulatory surgical center (ASC)-based; or a small practice

QPP Exceptions

There may be circumstances out of your control that make it difficult for you to meet program requirements. CMS provides the opportunity to apply for the QPP Extreme and Uncontrollable Circumstances Exceptions for MIPS (for any of the 4 MIPS performance categories) or the Promoting Interoperability Hardship Exception (for only the Promoting Interoperability performance category) only. Exception Applications may change each Performance Year (PY) due to changing policies.

Facility-Based Determinations

Beginning with the 2019 performance period, CMS will identify practices and clinicians eligible for facility-based scoring.

Facility-Based Practices

If a practice is identified as facility-based and is attributed to a facility with a Hospital Value-Based Purchasing (VBP) Program score, the practice will not be required to submit data for the Quality performance category. Instead, the Hospital VBP score will be used for the Quality and Cost performance categories as long as the practice submits group-level data for the Improvement Activities and/or Promoting Interoperability performance categories.  A facility-based practice could also submit Quality data via another collection type and CMS will use whichever data set results in a higher combined Quality and Cost score for the practice.

Facility-Based Clinicians

If a clinician is identified as facility-based and is attributed to a facility with a Hospital Value-Based Purchasing (VBP) Program score, the clinician is not required to submit data for the Quality performance category. The Hospital VBP score will be used for both the Quality and Cost performance categories instead.  The clinician could also submit individual Quality data via another collection type and CMS will use whichever data set results in a higher combined Quality and Cost score for the clinician.

Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration

The MAQI demonstration is testing waiving MIPS reporting requirements and payment adjustments for clinicians who participate sufficiently in Medicare Advantage (MA) arrangements that are similar to Advanced APMs. The demonstration looks at whether waiving MIPS requirements would increase levels of participation in MA payment arrangements and whether it would change how clinicians deliver care.

Quality Measures Reporting Study

Each year, CMS conducts a study (“The CMS Study on Factors Associated with Reporting Quality Measures”) on the workflows and data collection associated with reporting Quality measures.  Study participants receive full credit in the Improvement Activities performance category if they submit an application and successfully meet all of the study participation requirements.  Upon successful completion, those participants will be identified on the Participation Lookup Tool as receiving the “IA Study Credit.”