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Three Days Left to Request 2019 MIPS Targeted Review 

by Beth Pitman

Published: October, 2020

Submission: October, 2020


Individuals who participated in the Centers for Medicare and Medicaid (“CMS”) Quality Payment Program Merit-based Incentive Payment System (“MIPS”) in 2019 may request a Targeted Review of their performance feedback, including their MIPS final score and payment adjustment factor at the Quality Payment Program website.

In July, CMS released the MIPS Performance Feedback and scores for eligible providers. The MIPS score determines the payment adjustment participating providers will receive in 2021, with a positive, negative, or neutral payment adjustment being applied to the Medicare paid amount for covered professional services furnished by the MIPS eligible provider in 2021. The CMS 2019 Targeted Review Guide is located in the announcement on the CMS QPP Webpage here.

Targeted Review is requested based on reporting status for 2019, individual eligible clinician, group or Advanced Payment Model. For healthcare providers who acquired a group or employed a provider in 2020 and the acquired group or provider reported under MIPS in 2019, you will need access to the prior group or individual MIPS report and data submitted for the 2019 performance period and the Healthcare Quality Information System (HCQIS) Access Roles and Profile (HARP) account.

CMS has identified the following information as needed for a Targeted Review:

  • Access to the HARP account (and the account used for an acquired group or provide)
  • Clinician, group, virtual group, or APM participants identifying information.
  • Clinician – NPI and associated practice’s legal practicing name
  • Group – The practice’s TIN and legal practicing name
  • APM Entity ID for an Individual clinician, group or APM Entity participating in an APM
  • Approved virtual group – Virtual Group ID
  • Collect any documentation that supports your Targeted Review request. If possible, attach supporting documentation with your initial request. Supporting documentation may include, but is not limited to:
  • Extracts from the MIPS eligible clinician’s Electronic Health Records
  • Copies of performance data provided to a third-party intermediary by the clinician or group
  • Copies of performance data submitted to CMS - QPP Service Center case numbers
  • Signed contracts or agreements between a clinician/group and a third-party intermediary
  • Proof of your APM participation
  • Partial Qualifying APM Participant (QP) election forms

If MIPS eligible providers believe that an error has occurred in their MIPS payment adjustment factor calculation and their final score should be higher, they may request that the Centers for Medicare & Medicaid Services (CMS) review the final score calculation through a process called Targeted Review. The deadline to submit a request for Targeted Review is October 5, 2020 at 8:00 p.m (EDT).

Examples of Targeted Review circumstances include, but are not limited to, the following:

  • Errors or data quality issues for the measures and activities submitted
  • Eligibility and special status issues (e.g., falling below the low-volume threshold and, thus, should not have received a payment adjustment)
  • Erroneous exclusion from the APM participation list and not being scored under the APM Scoring Standard
  • Performance categories not automatically reweighted even though the provider qualifies for automatic reweighting due to extreme and uncontrollable circumstances

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