Facility-Based Scoring: Your 2019 MIPS Safety Net

By Stephen Besch, Director of Clinical Quality Reporting

After a few years of relative stability, changes are afoot once again within the MIPS program. As might be expected, many of these changes reflect a “good news / bad news” scenario. We’ll talk more about the bad news in a future blog entry, but here I want to focus on a new safety net that could protect you from penalties – even if you’re affected by one of the “bad news” changes.

What is MIPS facility-based scoring?

Beginning with the 2019 program year, if a clinician or group is classified as facility-based, CMS will compare their combined scores from the MIPS Quality and Cost categories against the scores their facility received under the FY 2020 Hospital Value-Based Purchasing Program, or HVBP. If the facility’s scores are higher than the clinician’s, CMS will automatically apply them to the clinician’s Quality and Cost categories under MIPS.

For example, if a clinician had difficulty sending sufficient MIPS Quality data to CMS during the year (or even if they submitted no Quality data at all), their hospital’s HVBP score could still help them avoid MIPS penalties. And it all happens automatically – there is no application or self-election process necessary to receive the benefits of facility-based scoring.

Who qualifies as a facility-based clinician?

To qualify for CMS’s facility-based designation as an individual, you must meet three criteria:

  1. You billed 75 percent or more of your covered services in an inpatient setting (using Place of Service codes 21 – inpatient hospital, 22 – on-campus outpatient hospital or 23 – emergency room).
  2. You had at least one service billed to CMS under POS codes 21 or 23 during the year.
  3. You can be attributed to a facility with a 2020 HVBP score.

If an individual clinician meets these three conditions, CMS will automatically classify them as a facility-based clinician. A group would automatically be qualified as facility-based if 75 percent of their individual clinicians attained facility-based status.

How does the attribution process work?

An individual clinician is attributed to the facility in which they provided the largest number of covered services during the year. A group would be attributed to the facility to which their largest number of individual clinicians were attributed.

It’s important to keep in mind that, while an individual or group may be attributed to a facility successfully, that facility must also have a valid HVBP score. This allows CMS to calculate a facility-based score for MIPS participants attributed to that facility. If attribution isn’t possible, or if the clinician is attributed to a facility without an HVBP score, a facility-based MIPS score will not be available for the clinician.

How can I determine if I’m facility-based?

Any clinician can check their facility-based status on the QPP Participation Status page. It will indicate if they qualify for facility-based scoring as an individual; it will also show if their group qualifies. The facility to which they’ve been attributed will also be on this page.

As noted above, if 75 percent of individuals in a group are classified as facility-based, the group qualifies for facility-based scoring. But group facility-based status is different from the “hospital-based” designation CMS uses elsewhere within the MIPS program. “Hospital-based” classification re-weights the Promoting Interoperability category to 0 percent, but requires 100 percent of the individuals within the group to be classified as hospital-based before the group can be classified as such.

For example, a group with 90 percent of their individual clinicians qualifying as both facility-based and hospital-based would be classified as a facility-based group but would not be classified as a hospital-based group. They would receive the benefits of facility-based scorings, but their Promoting Interoperability category would not be re-weighted to 0 percent. They would still need to submit PI data if participating in MIPS as a group.

It is also important to note that in every case (regardless of their facility-based or hospital-based designations), clinicians and groups should still submit data under the Improvement Activities category for MIPS. Failure to do so would automatically forfeit 15 available points for that category. Given that a total score of 30 points is needed to avoid all MIPS penalties for 2019, those 15 points would represent a significant loss.

Can I see my facility’s score?

Due to incongruities between the time periods and terminologies used in the HVBP and MIPS programs, the facility’s 2020 HVBP score would replace 2019 MIPS results under the facility-based scoring system. Since the 2020 HVBP scores for facilities won’t be available until January 2020, CMS is currently posting each facility’s 2019 scores on a preview page.

Facility-based clinicians can sign into the QPP website to review their facility’s 2019 scores. (Details about that process are available below.) While they can’t yet view the official 2020 HVBP scores for their facility, the 2019 scores can still provide a strong indication of how well their facility might score under HVBP in 2020.

Where can I learn more?

CMS provides two key sources of information: the Facility-Based Measurement Fact Sheet and the Facility-Based Preview FAQ. The Fact Sheet contains general information about the facility-based scoring process, while the Preview document focuses more on accessing your facility’s scoring preview and interpreting their HVBP score in relation to your MIPS participation. I highly recommend reviewing both documents thoroughly.