API doesn't support multiple performance periods

[Dave Rhoadarmer]

It looks like the API allows only one performance start & end date for the entire submission.  However, according to page 77015 of https://www.gpo.gov/fdsys/pkg/FR-2016-11-04/pdf/2016-25240.pdf, we are allowed to submit a different start/end for each measure.  Is this a policy change or an oversight or ... ?

See quoted text below:

"Within each performance category, we are finalizing specific requirements for full participation in MIPS which involves submitting data on quality measures, improvement activities, and use of certified EHR technology on a minimum of any continuous 90 days up to the full calendar year in 2017 in order to be eligible for a positive MIPS payment adjustment. It is at the MIPS eligible clinician’s discretion whether to submit data for the same 90-day period for the various measures and activities or for different time periods for different measures and activities."

[Dave Rhoadarmer]

Bumping this thread since almost all my other posts generated timely responses.

Are there plans to support different time periods per measure, as required by CMS?

[steven....@semanticbits.com]

Hey Dave, at this point, you can submit performance period data at the measurementSet level, are you looking to submit at the measure level? If so, is there a reason why you would like this to be implemented? Is this only in relation to Quality, or all categories? Once I get an understanding of exactly what you need, I can either respond or get clarification from CMS for you.

[Dave Rhoadarmer]

See the CMS text I quoted below.  It finalized that doctors are allowed to maximize their scores by cherry-picking their best 90 day periods for each measure and submitting:

   Jan-Mar performance numbers for one Quality measure

   Jun-Oct performance numbers for a 2nd Quality measure

   Jan-Dec for a 3rd

   Feb-Jun for a 4th

   etc.

The API currently allows a single timeframe for all of Quality, rather than individual timeframes by measure.

This also applies to ACI and IA.

Note that this will likely also apply for 2018 -- they have proposed keeping the 90 day minimum for some categories for yet another year.

[iv...@navahq.com]

Hi Dave - 

Thanks for the details. 

Currently, the API allows for one performance start and end date per submission method and submitter. For example, if you are submitting as a registry, you can submit:

• Jan-Mar for quality
• June-Oct for ACI
• Jan-Dec for IA

Note: a submission object - which contains all data submitted on behalf of a doctor or practice - can contain all of the above, plus quality, ACI and IA data submitted by other organizations.

Steve and I will take this back to CMS, and confirm whether your interpretation is correct. We'll circle back here, when we have an answer.

Thanks,

Ivana

[iv...@navahq.com]

Hi Dave - 

We consulted the Policy Team at CMS. The intent of that excerpt in the QPP Final Rule is to say that submitters may use different time periods for each category. So the API is interpreting the policy correctly.

However, I want to point out that a submission object can contain multiple category measurement sets (e.g. multiple quality sets) with varying performance periods - as long as the submission method for each set is different. For example, a submission can contain:

• Quality measurement set Q1, Jan - Dec, submitted by registry
• Quality measurement set Q2, June - Oct, submitted by EHR

-Ivana