QPP Roundup: July 2018

PAI's QPP Tip of the Month: An Updated Look-Up Tool

CMS updated the Quality Payment Program (QPP) Look-Up Tool with 2018 Merit-based Incentive Payment System (MIPS) eligibility and Qualifying Alternative Payment Model (APM) Participant (QP) data. You can enter your National Provider Identifier (NPI) to determine: 1) whether you are required to participate in MIPS in 2018 and 2) your Predictive QP status.


You can also check 2018 MIPS eligibility at the group level and APM Predictive QP status at the APM entity level by logging into the QPP website with your Enterprise Identity Data Management credentials and the Taxpayer Identification Number (TIN) affiliated with your group. By doing so, you can access the details screen to view and download the eligibility status based on each NPI.


For additional information, please refer to the Predictive QP Methodology Fact Sheet, recently posted in CMS’s Resource Library here or contact the Quality Payment Program Service Center at or 866-288-8292 (TTY: 877-715-6222).

Please find PAI’s comprehensive resource here for a refresher on the 2018 MIPS Scoring Overview.

Requests for Targeted CMS Review: 2019 MIPS Payment Adjustment Factor Calculation

Do you believe an error has been made in your 2019 MIPS payment adjustment calculation (based on 2017 MIPS participation)? Until September 30, 2018, you can request that CMS review your MIPS payment adjustment, or additional MIPS payment adjustment.

If your organization’s answer to any of the questions below is “yes,” you might consider requesting a targeted review from CMS. Please note that this list is not intended to be comprehensive.

  • Were there data quality issues or errors on the measures and activities you submitted?

  • Were there eligibility issues that affected your qualification for payment adjustments?

  • Was there an erroneous exclusion from the APM participation list that as a result, you were not scored under the APM scoring standard?

  • Did you qualify for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy, but were not automatically reweighted?

For more information about how to request a targeted review, CMS published the Targeted Review of the 2019 MIPS Payment Adjustment Fact Sheet, as well as the Targeted Review of 2019 MIPS Payment Adjustment User Guide.

Promoting Interoperability Hardship Exception Application Window Opens August 1!

As part of the Promoting Interoperability performance category of QPP (formerly the Advancing Care Information (ACI) category), MIPS eligible clinicians (ECs) and groups may submit a Hardship Exception Application, citing any of the reasons specified below for review and approval:

  • MIPS ECs in small practices (defined as 15 or fewer ECs)

  • MIPS ECs using decertified EHR technology

  • Extreme and uncontrollable circumstances

  • Insufficient connectivity to Internet

  • Lack of control over CEHRT availability

You can apply for a hardship exception for 2018 MIPS participation in the Promoting Interoperability category from August 1, 2018, through December 31, 2018. Learn more about the Hardship Exception with this CMS resource here and PAI’s overview on the Promoting Interoperability Category Hardship and Reweighting resource. For more information on the Promoting Interoperability performance category, please review PAI’s Promoting Interoperability Overview resource.

CMS Advances the Medicare Advantage Qualifying Payment Arrangement Incentive  Demonstration


CMS is advancing this demonstration, under which eligible clinicians (as defined under the QPP) participating extensively in Advanced APM-like arrangements under Medicare Advantage would be exempt from MIPS reporting and payment consequences for a given year. Proposed to begin this year, the demonstration would last for five years. If it moves forward, CMS hopes to test whether exempting qualified clinicians from MIPS requirements affects clinician participation in payment arrangements and healthcare delivery. CMS is inviting public comment through Tuesday, August 28 on the potential information collection burdens associated with the demonstration. PAI will review the announcement and provide detailed feedback to CMS. Read CMS’s announcement here and the request for comments here.

CMS QPP Updates

CMS posted several new fact sheets to its QPP Resource Library:

CMS Upcoming QPP Webinars


  •  MIPS Cost Performance Category for Year 2 webinar – Wednesday, July 25, 2018, 1:00 – 2:00 p.m. ET. Registration for the webinar is available here.

  • MIPS Improvement Activities Performance Category for Year 2 webinar – Wednesday, August 1, 2018, 1:00 – 2:00 p.m. ET. Registration for the webinar is available here.

  • MIPS Quality Performance Category for Year 2 webinar – Monday, August 6, 2018, 1:00 – 2:00 p.m. ET. Registration for the webinar is available here.