MIPS: Understanding and addressing topped-out measures

One aspect that practices may face as they conduct their quality reporting under CMS’s Merit-based Incentive Payment System (MIPS) in 2018 are “topped-out measures.”

As you know, this year’s MIPS guidelines require practices to report on a number of categories in order to be evaluated and receive additional reimbursements under the Quality Payment Program (QPP). In MIPS, categories are weighted differently, with the Quality category accounting for 50 percent of the final score practices receive (the most-weighted category in the 2018 reporting period).

Practices will select six quality measures to report on from more than 200 available measures within the Quality category. “Topped-out measures” are specific quality measures in which-according to CMS-“meaningful distinctions and improvement in performance can no longer be made.” For example, a process measure (which make up half of all measures) would be topped-out if median performance is 95 percent or higher-or 5 percent or lower if it is scored inversely, both of which would be deemed too easily attainable.

Topped-out measures may make it difficult for practices to receive the maximum number of points under the QPP, but by identifying measures as topped-out, CMS is incentivizing practices to choose other measures where considerable performance improvement is more likely.

Looking ahead, CMS will continue to identify and top out measures that do not offer MIPS-eligible clinicians significant improvement opportunities. Once identified, measures will be phased out over a four-year timeline consisting of capping the measure to a lower maximum score, followed by the measure’s removal entirely.

However, some topped-out measures may remain in the program for longer than four years as CMS considers the maintenance of measures that contribute important aspects of patient safety and reliability.

What can practices do to prepare?

1. Compare the current 2018 MIPS Quality Benchmarks.
Current benchmarks can help determine if a quality measure is topped-out. An example of a commonly reported topped out measure is Documentation of Current Medications (Quality Measure ID 130), which is topped-out for all methods of reporting but does not yet have capped scoring. Variance in decile scoring is so limited that one performance mistake could lose you several points, depending on the method of reporting. If a practice is reporting this measure through a qualified registry or QCDR, they can only score 10 points if they score 100 percent, a perfect performance. Any score of 99.99 percent or less would drop the practice down to the 7^th decile (worth 7.0-7.9 points). That leaves practices no leeway in workflow errors, as just one patient missed could keep them from maintaining perfect performance.

Review the full list of 2018 topped-out measures here.

2. Review your numbers at least quarterly.
By reviewing the performance of their clinicians on a quarterly basis, practices can make course corrections throughout the year to ensure they are meeting necessary performance standards. Practices that notice early on that they are not meeting the standards they have selected through their reporting can either select other measures that they might be better suited for reporting or implement processes that allow them to improve their performance before the end of the year.

3. Select the appropriate measures.
Due to topped-out measures’ scoring limitations, successful practices should carefully consider and select measures that show improvement in performance. For example, Quality ID 236 (Controlling High Blood Pressure) is a high-priority measure practices can select and work with their patients to improve over time. Measures that continue to show meaningful improvement in performance by practices will likely have a longer time span in the MIPS program.

Additionally, practices do not need to look for the easiest measure to meet-or to achieve a “perfect” score as other practices could potentially be doing the same (which then creates a high benchmark that may demonstrate little variance and lead to further top outs). There are many non-topped-out measures where practices can earn the full 10 points without scoring a perfect or close-to-perfect performance.

4. Engage an expert quality reporting team.
One way practices can maximize their reimbursement without losing valuable time with patients is to work with a quality reporting engagement team. This team can assist with guidance on how to understand changing quality measurements, avoid costly missteps, and maintain peace of mind.

CMS will continue to select additional high-performing measures to top out in coming years, impacting a practice’s ability to maintain high MIPS scores above the performance threshold. Engaging an expert reporting engagement team will allow practices to address these changes head-on while remaining committed to providing quality care to patients.

Jackie Rogers is the manager of the Quality Reporting Engagement Group at data analysis provider IntrinsiQ Specialty Solutions, a part of AmerisourceBergen.