How to Participate in MIPS using Telehealth
The COVID-19 pandemic has increased practices’ use of telehealth services to provide safe, quality care to patients. Many services normally provided in-person can be provided via telehealth, including office visits, mental health counseling, and preventive health screenings. You can view a full list of telehealth services here.
Considering the major shift from traditional office visits to telehealth services, many practices are wondering how telehealth will affect their MIPS participation moving forward. In particular, understanding which quality measures and improvement activities are included in telehealth services will help your practice succeed in MIPS.
Telehealth and Quality Measures
Approximately one-third of the 2020 quality measures include telehealth visits. To meet the 20-case minimum requirement and capture as many telehealth visits as possible, practices should select the quality measures that include telehealth visit codes. You can refer to the 2020 Measure Specification Sheets and Supporting Documentation to learn which quality measures use telehealth visit codes. A few things to keep in mind:
- The patient encounter code must use an approved telehealth code. Note: the current list includes 240 codes.
- The patient encounter cannot state “WITHOUT Telehealth Modifier GQ, GT, 95, POS 02.”
If you’re not sure what codes are required for your selected MIPS measures, you can refer to the 2020 Measure Specification Sheets and Support Documentation for details.
Telehealth and Improvement Activities
There are many improvement activities that can be performed via telehealth, including Annual Wellness Visits (AWVs). Providers can use video conferencing or audio-only technology to conduct an AWV, as long as the platform is secure and providers are practicing in good faith. More information on CMS’s policy on telehealth remote communications during COVID-19 can be found here. In addition, patients can self-report vitals during an AWV conducted via telehealth, as long as they are documented as self-reported. Lastly, Hierarchical Condition Coding (HCC) with the AWV continues to be acceptable just as it was with face-to-face visits. Other relevant improvement activities include:
- IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record (high activity weight)
- IA_EPA_2: Use of telehealth services that expand practice access (medium activity weight)
- IA_ERP_3: COVID-19 Clinical Trials (high activity weight)
For more information on telehealth services, you can listen to and view the QPP SURS May LAN Webinar, Understanding How to Implement Telehealth Services: Implications for Solo and Small Group Practices. In addition, for information on telehealth and billing, review the Medicare Telehealth and Remote Patient Monitory Coding and Guidelines Toolkit or contact your Medicare Administrative Contractor. If you need assistance, do not hesitate to reach out to your Technical Assistance Contractor for free personalized support. Find your Technical Assistance Contractor here.
2020 Quality Measures List for with Telehealth Guidance
CMS recently published a list of quality measures that includes telehealth for the 2020 performance period. When reviewing this list of quality measures, please note there may be instances where the quality action cannot be completed during the telehealth counter by MIPS-eligible clinicians and group practices. Specifically, telehealth eligible Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes may be included within the measure denominator, where the required quality action in the numerator cannot be completed via telehealth. For example, Q111: Pneumococcal Vaccination Status for Older Adults may require the administration of the pneumococcal vaccination at the denominator eligible encounter in order to meet performance for the measure. Therefore, it is the MIPS-eligible clinicians, groups, and virtual groups’ responsibility to make sure they can meet all other aspects of the quality action within the measure specification, including other quality actions that cannot be completed by telehealth. For more information, please review the Telehealth Guidance for Medicare Part B Claims and MIPS Clinical Quality Measure (CQMs) for 2020 Quality Reporting.