QPP Reporting for Hospitals & Health Systems

Under the Quality Payment Program, clinicians are reimbursed for Medicare Part B services based on their participation in the Merit Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs). Performance under both tracks can result in a positive or negative payment adjustment to reimbursement rates for Medicare Part B services.

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Hospitals and Health Systems face especially unique challenges when navigating these new requirements. The reimbursement of Medicare Part B services depends directly on the performance of each eligible department, clinic, and clinician. Accessing multiple Electronic Medical Records or billing software to get the right data from the right providers is another challenge, but crucial to successful reporting.  Hospitals must also critically assess reporting options, determine clinician eligibility, and make the decision about whether to report as an individual or as a group, as these factors will impact the ease of reporting and overall reimbursement.

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Should you opt for Facility-Based Scoring?

Hospitals and Health Systems should also consider the pros and cons of facility-based measurement, a participation option launched by CMS in their 2019 MACRA final rule that offers certain groups of facility-based clinicians the option to be scored based on their hospital’s overall performance. If these clinicians additionally decide to report MIPS quality measures in the standard way, CMS will award them the higher of the two scores.

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Under facility-based measurement, individual clinicians can avoid reporting their own Quality measures but have no control over what measures and score they will ultimately receive, and less influence over facility-level performance improvement. Clinicians focused on MIPS incentive maximization should therefore choose a reporting mechanism that better enables performance improvement, like a Qualified Registry or QCDR.