Does Your Practice Have a MIPS Strategy for Performance Year 2021?

The submission window for MIPS Performance Year (PY) 2020 closes on March 31, 2021. As one year closes another begins, and now is the time that practices should be preparing for their 2021 MIPS reporting. For the new year, the MIPS annual program requires submission of data in four categories—Quality, Promoting Interoperability (PI), Improvement Activities (IA) and Cost. In this blog, we will briefly go over actions to be taken throughout the year for submission in PY 2021 so that our readers can be better prepared for the next MIPS reporting period.

FOR MORE DETAILED INSTRUCTIONS, CHECK OUT OUR “2021 MIPS CHECKLIST” INFOGRAPHIC

January to March 2021

For the initial three months of the year, practices should be performing the following to plan and prepare:

• Confirm the eligibility for MIPS 2021 for each of your practice’s providers.
• Determine if your practice will be reporting as individual providers or altogether as a group.
• Establish your practice’s MIPS strategy to ensure maximum MIPS points for 2021.
• Review and confirm reporting requirements for all four MIPS categories for 2021: Quality, Promoting Interoperability (PI), Improvement Activities (IA) and Cost.
• Confirm the submission options available to your practice and evaluate which measures are available for your practice to report on for MIPS 2021: Direct EHR, Registry or Claims.
• If you are not already using a registry, you should research registry options now to meet your PI requirements.

April to September 2021

For the next six months, practices should continue tracking and reviewing data by performing the following steps:

• Continue monthly reviews of your data results for the quality measures you chose at the beginning of the year as part of your MIPS 2021 strategy.
• Continue monthly reviews of your data results for PI measures that are required as part of your MIPS 2021 strategy.
• Identify gaps in measure reporting and create meaningful action plans to address these areas as soon as possible.
• Track information for Improvement Activities (IA) attestations.
• Complete the required Security Risk Assessment (SRA) for the Promoting Interoperability category (this needs to be dated in 2021).

October to December 2021

For the final three months of the year, it is time to review and finalize your reporting data with the following steps:

• Be sure the IA and PI measures need to be started no later than October 1, 2021 to complete the required 90-day performance period.
• Review all steps throughout the reporting calendar year to catch up and satisfy reporting requirements on time.
• Review and confirm all data being prepared for attestation is valid and has solid documentation for auditing purposes.
• Identify and select the top six quality measures your practice will be submitting to CMS for the MIPS 2021 performance year.
• Confirm that the final scores reflect the data that was submitted and take screenshots for confirmation once final data is submitted to CMS.
• Review any changes in the MIPS program for the next year to begin the process anew in the 2022 MIPS performance year.

With each passing year, CMS continues to support MIPS while adding new changes and improvements to the program. By planning out and executing a MIPS strategy each year, and following the steps outlined in this blog and our new infographic, your practice can avoid being caught off guard by these changes, helping you to avoid penalties while ensuring you are maximizing your annual scores and reimbursements.

To learn how Nextech’s team of regulatory experts can help your specialty practice achieve MIPS compliance, fill out this form and a member of our team will be in touch soon!