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Clinicians who disagree with their MIPS score will need documentation to make their case

Clinicians who participated in the first year of the merit-based incentive payment system (MIPS) have until Sept. 30 to dispute CMS’ calculations. But they should keep two words in mind: supporting documentation.
A targeted review is a process where MIPS-eligible clinicians or groups can request that CMS review the calculation of their 2019 MIPS payment adjustment factor and, as applicable, their additional MIPS payment adjustment factor for exceptional performance.
Clinicians — or the person authorized to act on a clinician’s behalf — should be prepared to prove that CMS made a mistake. CMS makes that clear in the four examples of why a MIPS-eligible clinician — or group — might request the review:
  1. The clinician has supporting documentation that indicates there were calculation errors or data quality issues in the measures or activities he submitted directly or through a third-party, such as a registry.
  2. The clinician has supporting documentation that she was subject to a MIPS exemption. For example, she fell below the low-volume threshold and should not have received a payment adjustment.
  3. The clinician has supporting documentation that shows he is covered by the 2017 extreme and uncontrollable hardship policy and his performance categories should have been automatically reweighted.
  4. The clinician has supporting documentation indicating that she should have been scored under the alternative payment model (APM) scoring standard.
The list isn’t comprehensive, CMS explained. Targeted review is appropriate for any providers who reviewed their final performance feedback and “can provide supporting documentation” that their MIPS payment adjustments warrant targeted review.
Once you submit your targeted review request through the enterprise identity management portal, keep an eye out for an additional documentation request. You’ll have 30 calendar days to send the information if you want to keep your review going.
Examples of supporting documentation include:
  • Extracts from the clinician’s electronic health record.
  • Copies of performance data provided to a registry or submitted to CMS.
  • Quality payment program service center ticket numbers.
  • Signed contracts or agreements between a clinician/group and a third-party intermediary.
  • APM participation agreements.
  • Partial QP election forms.
Be prepared to verify that you’re sending exactly what CMS wants. This will be your last chance to make your case.
Targeted review decisions are final and not eligible for further review.
For more details on the targeted review process, check out the targeted review user guide, which was issued yesterday.
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