Quality Payment Program: 2019 Performance Period Suppressed MIPS Quality Measures

In the Calendar Year (CY) 2019 Physician Fee Schedule Final Rule (83 FR 59847), the Centers for Medicare & Medicaid Services (CMS) established a policy that provides for the suppression of measures in certain circumstances.  Starting with the 2019 performance period, for measures significantly impacted by clinical guideline changes or other changes where we believe that adherence to guidelines in the existing measures could result in patient harm or otherwise cause misleading results as to what is measured as good quality of care, we will reduce the denominator of available measure achievement points for the quality performance category by 10 points for each impacted measure that is submitted by MIPS eligible clinicians and groups.  Such policy will “hold harmless” any clinician or group submitting data on a suppressed measure.

The measures identified below have been suppressed under § 414.1380(b)(1)(vii), which is limited to the 2019 MIPS performance period. In order for the impacted measures to reflect the clinical guideline changes, CMS updates the impacted measures through the rulemaking process.

2019 Quality Measure Suppression List

Quality Measure Number/Title Collection
Type Impacted
Guideline Changes and Suppression Rationale
Measure 69:
Hematology: Multiple Myeloma:
Treatment with Bisphosphonates
MIPS CQM Guideline Change Impact: The updated National Comprehensive Cancer Network (NCCN) Guidelines for Multiple Myeloma recommend bisphosphonates (Category 1 Recommendation) or denosumab for all patients receiving myeloma therapy for symptomatic disease regardless of documented bone disease. Denosumab is preferred by the NCCN Panel in patients with renal disease. (NCCN, 2020). For the MIPS 2019 performance period, eligible clinicians may utilize the denominator exception of a medical reason for the use of denosumab, as previous guidelines recommended bisphosphonates for all patients receiving myeloma therapy for symptomatic disease, not including the option of prescribing denosumab.

Suppression Rationale: The clinical guideline change that supported the use of denosumab was made between rulemaking cycles and as a result, the updated clinical guideline is not compatible with the existing guidance in the 2019 measure specification, which could cause misleading results as to what is measured as good quality of care. Therefore, this measure will be suppressed

Measure 110:
Preventive Care and Screening:
Influenza Immunization
Medicare Part B Claims
MIPS CQM
eCQM
CMS Web Interface
Guideline Change Impact: In 2018, the Centers of Disease Control (CDC)/Advisory Committee on Immunization Practice (ACIP) updated clinical guidelines to include the recommendation that live attenuated influenza virus was acceptable for the 2018-2019 influenza season.

The 2019 measure specification states the following: As a result of updated CDC/ACIP guidelines which include the interim recommendation that live attenuated influenza vaccine (LAIV) should not be used due to low effectiveness against influenza A (H1N1) pdm09 in the United States during the 2013-14 and 2015-16 seasons, LAIV or intranasal flu vaccine is no longer an option for numerator eligibility.

Suppression Rationale: The clinical guideline change that supported the use of LAIV for the 2018-2019 influenza season was made between rulemaking cycles and as a result, the updated clinical guideline is not compatible with the existing guidance in the 2019 measure specification.  The 2019 measure specification includes guidance that does not include LAIV and could cause misleading results as to what is measured as good quality of care.  Therefore, this measure will be suppressed.

Measure 450:
Trastuzumab Received By Patients
With AJCC Stage I (T1c) – III And HER2
Positive Breast Cancer Receiving Adjuvant Chemotherapy
MIPS CQM Guideline Change Impact: In January of 2019, the Food & Drug Administration (FDA) approved biosimilar drugs to trastuzumab.

Suppression Rationale: For the 2019 performance period, guidance for the use of biosimilar drugs to report as a denominator exception was not included as an available option within the measure specification. The clinical guideline change that supported the use of other biosimilar drugs as a treatment for AJCC Stage I (T1c) – III and HER2 Positive Breast Cancer was made between rulemaking cycles and as a result, the updated clinical guideline is not compatible with the existing guidance in the 2019 measure specification, which could cause misleading results as to what is measured as good quality of care.  Therefore, this measure will be suppressed.

 

Please direct any questions related to the measures suppressed for the 2019 performance period to the Quality Payment Program Service Center at QPP@cms.hhs.gov.

About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).