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Update on MIPS Measure Suppression


CMS MIPS HHS 2021 Quality

The Centers for Medicare and Medicaid Services (CMS) issued an important clarification on the measures being suppressed for 2021 MIPS reporting.

Background

In the 2019 MIPS rule, CMS finalized a policy to suppress any quality measure impacted by clinical guidelines changes during the performance year and to truncate to 9 months quality measures impacted by ICD-10 changes during the performance year. 

When a measure is suppressed, CMS reduces the denominator of the Quality category score by 10 points and does not count the measure in the Quality numerator for those who report that measure. When a measure is truncated, CMS only scores data from the first 9 months of the performance period.

In the 2021 MIPS rule, the suppression policy was expanded and clarified:

  • CMS will only suppress (subtract from the quality category numerator and denominator) measures impacted by clinical guidelines changes if fewer than 9-consecutive months of data can be collected OR if measure may result in patient harm or misleading results and to truncate the performance period of the remaining.
  • CMS will suppress measures impacted by coding (HCPCS or CPT) or measure specification changes (including the introduction of a new drug class) during the performance year if fewer than 9-consecutive months of data can be collected (otherwise they truncate the performance period).

At the end of 2021, CMS updated their list of suppressed measures to suppress or truncate several electronic clinical quality measures (eCQMs):

  • Measure 111: Pneumococcal Vaccination Status for Older Adults
    • Truncated due to clinical guidelines changes
  • Measure 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
    • Suppressed due to error in eCQM which caused misleading results

Widespread Confusion

We have recently received questions on what happens to measures suppressed for eCQM collection type. These questions cite reporting from other sources that those measures will not be allowed to be submitted at all. This was not our understanding, so we reached out to CMS for clarification.

Can You Still Report on Suppressed or Truncated eCQMs?

The short answer: Yes

If you submit measure 128 via eCQM, you will signal to CMS that the measure was intended to be 1 of the 6 for reporting requirements. Because the measure is suppressed, you will not be scored on the data received for the measure and your Quality category denominator will be reduced by 10 points. Out of the remaining measures you submit, CMS will use your highest scoring outcome/high priority measure and 4 remaining highest scoring measures.

If you submit measure 111 via eCQM, CMS will only score data from the first 9 months of the 2021 performance year, excluding October - December, 2021. 


Next Steps

  • Share this information with your practice colleagues.
  • Contact your Client Success Manager if you have any questions. 
  • If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

If you want hands-on, personalized assistance, contact us and we will have your back. 

 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Senior Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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