Table A-12. Unemployed persons by duration of …

However, we do not believe that applying the nominal amount standard at a level other than the APM Entity is operationally feasible at this point in time, and doing so in the other payer context may pose unique challenges relative to those we face under Medicare. Nevertheless, ideally, the nominal amount standard would take into consideration the resources available to an APM Entity using a measure such as revenue for the parent organization. We are evaluating the feasibility of implementing such a measure in lieu of APM Entity revenue for the third year of the program and later years. Under such an approach, we would anticipate basing the revenue-based nominal amount standard on the total revenues from a payer across the APM Entity, any parent organizations, any subsidiary organizations, and any subsidiaries of parent organizations for all eligible clinicians and groups who are participants of an APM Entity. We seek comment on this approach and how such an approach could be implemented while minimizing burden on participants.

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To earn points toward the base score, a MIPS eligible clinician must report the numerator and denominator of certain measures specified for the advancing care information performance category (see measure specifications in section II.E.5.g.(7) ( through 28228)), which are based on the measures adopted by the EHR Incentive Programs for Stage 3 in the 2015 EHR Incentive Programs final rule, to account for 50 percent (out of a total 100 percent) of the advancing care information performance category score. For measures that include a percentage-based threshold for Stage 3 of the EHR Incentive Program, we would not require those thresholds to be met for purposes of the advancing care information performance category under MIPS, but would instead require MIPS eligible clinicians to report the numerator (of at least one) and denominator (or a yes/no statement for applicable measures, which would be submitted together with data for the other measures) for each measure being reported. We note that for any measure requiring a yes/no statement, only a yes statement would qualify for credit under the base score. Under the proposal, the base score of the advancing care information performance category would incorporate the objective and measures adopted by the EHR Incentive Programs with an emphasis on privacy and security. We proposed two variations of a scoring methodology for the base score, a primary and an alternate proposal, which are outlined below. Both proposals would require the MIPS eligible clinician to meet the requirement to protect patient health information created or maintained by CEHRT to earn any score within the advancing care information performance category; failure to do so would result in a base score of zero, a performance score of zero (discussed in section II.E.5.g of the proposed rule (), and an advancing care information performance category score of zero.

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Comment: We received many comments on the allocation of points in the base score. Some commenters asked CMS to simplify the base score calculation and weight the base score higher. Alternatively commenters recommended that CMS reweight the base score to 75 percent of the total advancing care information performance category. Other commenters recommended that increasing the weight of the base score only occur if CMS also moves away from the pass-fail approach to scoring this section. Others suggested removing the base component of the scoring methodology, and instead just have a set amount of points that it is possible to achieve for each measure.

you will be able to triangulate across the multiple measures and get a more accurate sense of what's going on
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Response: To ensure meaningful measurement of patient experiences, we plan to include the CAHPS for MIPS survey as one way to earn bonus points since we believe this survey is important and appropriate for the Quality Payment Program. However, we would like to explain that the CAHPS for MIPS survey is optional for all MIPS eligible clinician groups, and that there are other ways for skilled nursing facilities to obtain bonus points, such as by reporting additional outcome measures or other high priority measures. We encourage stakeholders who are concerned about a lack of high priority measures to consider development of these measures and submit them for future use within the program. In addition, our strategy for identifying and developing meaningful outcome measures are in the quality measure development plan, authorized by section 102 of the MACRA (). The plan references how we plan to consider evidence-based research, risk adjustment, and other factors to develop better outcome measures.

Complexity Measures – an article about the abundance of not-that-useful complexity measures

Large variation across the United States

Under our final policy, MIPS eligible clinicians have the ability to earn an overall score for the advancing care information performance category of up to 155 percentage points, which will be capped at 100 percent when the base score, performance score and bonus score are all added together. We believe this addresses commenters' requests for additional opportunities to earn credit in all aspects of the advancing care information performance category including the base score, performance score and bonus score. In addition, we believe this scoring approach adds flexibility for MIPS eligible clinicians to choose measures that are most applicable to their practice and best represent their performance. While certain measures are still required for reporting, we have reduced this number from 11 required measures in the proposed base score to only five in this final policy. We have also increased the number of measures for which a MIPS eligible clinician has the ability to earn performance score credit from eight measures in the proposed performance score to nine in this final policy. We note that MIPS eligible clinicians can choose which of these measures to focus on for their performance score allowing clinicians to customize their reporting and score.

In addition to varying by family type, many costs vary widely by geographic area

Measures of Variability | Real Statistics Using Excel

To determine the MIPS eligible clinician's overall advancing care information performance category score, we proposed to use the sum of the base score, performance score, and the potential Public Health and Clinical Data Registry Reporting bonus point. We note that if the sum of the MIPS eligible profession's base score (50 percent) and performance score (out of a possible 80 percent) with the Public Health and Clinical Data Registry Reporting bonus point are greater than 100 percent, we would apply an advancing care information performance category score of 100 percent. For example, if the MIPS eligible clinician earned the base score of 50 percent, a performance score of 60 percent and the bonus point for Public Health and Clinical Data Registry Reporting for a total of 111 percent, the MIPS eligible clinician's overall advancing care information performance category score would be 100 percent. The total percentage score (out of 100) for the advancing care information performance category would then be multiplied by the weight (25 percent) of the advancing care information performance category and incorporated into the MIPS final score, as described at through 28271 of the proposed rule. Table 10 of the proposed rule () provides an example of the calculation of the advancing care information performance category score based on these proposals. For our final policy, we revised the proposed scoring approach by reducing the number of required measures in the base score and adding measures to the performance score in an effort to address commenters' concerns (as described above) and add flexibility wherever possible. The base score and performance score are added together, along with any additional bonus score if applicable, to determine the overall advancing care information performance category score.