MIPS Cost Performance Category

Accounts for 85% of Final MIPS Score in 2021 for RDNs due to CMS automatically reweighting the Cost and Promoting Interoperability performance categories for RDNs.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation authorized the end of the Physician Quality Reporting System (PQRS) in 2018 and the beginning of a new program, the Merit-based Incentive Payment System (MIPS), which subsumes PQRS. The 'Quality' category is essentially the "old" PQRS category, meaning the same measures that applied to RDNs under PQRS apply here. MIPS basically adopts the quality measures and reporting methods from the Physician Quality Reporting System (PQRS) and Value-based Payment Modifier (VBM) programs.

Reporting Requirements

Minimum reporting:

Report data from January 1 – December 31 on at least 70% of Medicare Part B patients who qualify for each measure.

Report at least 6 Quality measures. One must be an outcome measure or a high priority measure (if an outcome measure is not available that is applicable to your specialty or practice), or all applicable measures within the Nutrition/Dietitian specialty measure set. Note: RDNs are not limited to reporting only the measures included in the Nutrition/Dietitian specialty set. To learn more, view the Quality Measures Table (below).

To learn more about the Nutrition/Dietitian Specialty Measures Set, visit the Explore Measures Section of the QPP Website and select the 2021 Performance year. From there, select Nutrition/Dietitian from the Specialty Set drop-down list.

Groups using the CMS Web Interface (group of at least 25 clinicians): Report all Quality measures included in the CMS Web Interface measures collection type for a full year. Note: CMS will Sunset the CMS Web Interface beginning in 2022.

Groups in APMs qualifying for special scoring under MIPS, such as the Comprehensive Primary Care Plus Model or the Oncology Care Model: Report Quality measures through your APM. You do not need to do anything additional for MIPS Quality.

RDNs may not have six measures to report under Quality depending on the collection type used. In that case, CMS will accept the measures that do apply to the RDN practice as meeting the requirement.

Deciding Which Quality Measures to Report

Quality ID Measures for RDNs

The specific Quality measures you report will depend on two things:

  1. Whether you are submitting data as an individual or as a group.
  2. The mechanism (known as collection type) you are using to submit data.

Collection Type refers to the way data is collected for a quality measure. There are currently 5 collection types that RDNs can utilize to collect quality measure data for reporting:

  • Electronic Clinical Quality Measures (eCQMs)
  • MIPS Clinical Quality Measures (CQMs)
  • Medicare Part B Claims Measures
  • CMS Web Interface Measures
  • Qualified Clinical Data Registry (QCDR) Measures

View a chart showing collection types for detailed information on each collection type.

Individual quality measures may be collected in multiple ways, however each collection type has its own specification (instructions) for reporting (submitting) that measure. Some quality measures can be reported by either claims or registry, while others are only available to be reported via registry. For example, of the seven quality measures available to RDNs, there are only 4 Quality measures you can submit via claims, three measures available to submit via Electronic Health Record, and all seven measures are available to submit via Registry. It is important to follow the measure specifications that correspond with how you choose to collect your quality data.

Quality Measures can be submitted utilizing more than one submission collection type. Your submitter type (the person, group or intermediary who submits data) may play a role in determining what submission collection type is utilized.

The Quality ID Measures for RDNs table (see below) cites the collection types available for each measure. Note that only small practices (less than 15 ECs) can submit Quality measures via Medicare Part B claims.

The Quality Measures Table lists a sample of measures that fall within the scope of practice for RDNs and are listed by collection type. You will note that the measures are reported only once a year with the exception of Quality ID# 130, Documentation of Current Medications in the Medical Record, which is recorded each visit.

Submitting Your Quality Data

  • Quality Measure Data can be submitted by an individual, group, virtual group, or APM Entity Representative; data can also be submitted by a Third-Party Intermediary or by a CMS Approved Third Party Vendor.
  • CMS will score each measure based on the most successful collection type.
  • CMS recognizes the following submission types for quality measures:
    • Medicare Part B Claims
    • Sign in and upload
    • CMS Web Interface**
    • Direct Submission via Application Programming Interface (API)
      • API includes: Electronic Health Record or Qualified Registry

**Note: CMS Web Interface is available to large group practices and will be sunset in 2022.

Medicare Part B Claims Reporting

This collection type is only available for small practices (less than 15 ECs). Simply start reporting the quality-data codes (QDCs) listed in the individual measures you have selected on applicable Medicare Part B claims. For each Quality measure, there is an associated list of QDCs, each one specifying a level of performance on that measure. Most measures applicable to RDNs only need to be reported a minimum of once per year on each Medicare patient seen (exception: Quality ID #130 needs to be reported for each visit):

  • Complete claim(s) with codes for reimbursement.
    • Quality Sample CMS1500 Claim Form
    • QDCs are specified Current Procedural Terminology (CPT) Category II codes (with or without modifiers) and Healthcare Common Procedure Coding System (HCPCS) G-codes used for submission of Quality data. They are non-payable, alpha-numeric codes used solely for the purposes of reporting Quality data via claims-based and registry-based reporting.
    • EPs must include a $0.01 line-item charge for the QDC. This is a new requirement for quality reporting via claims to CMS.

Please note: Claims may not be resubmitted for the sole purpose of adding or correcting QDCs. Reference measure specifications at Explore Quality Measures.

  • Do a double check.
  • Review your Remittance Advice (RA)/Explanation of Benefits (EOB).
    • Review your claims for accuracy prior to submission for reimbursement and reporting purposes.
    • Review your RA/EOB for denial code N620. This code is your indication that the Quality codes were received into the CMS National Claims History (NCH) database. The accompanying message is "Alert: This procedure code is for quality reporting/informational purposes only." Claims with a QDC line-item charge of $0.01 or more will also generate claim adjustment reason code (CARC) 246. The accompanying message is "This non-payable code is for required reporting only."
    • Please note: If all billable services on the claim are denied for payment by the Carrier or A/B MAC, the QDCs will not be included in MIPS analysis.
    • Claims processed by carriers or A/B MACs must reach the NCH file by March 31, 2021 to be included in the 2020 MIPS analysis.

Sign In and Upload

Eligible Clinicians (including individual clinicians, group practices, virtual group, or APM Entity Representatives) and Third-Party Intermediaries may choose to submit quality measures on their own by logging into the QPP website and uploading data directly to CMS. Those electing to submit quality measures via Sign In and Upload, must be credentialed with the HCQIS Access Roles and Profile system (HARP). To Learn more, visit the QPP Account Page.

Direct Submission via Application Programming Interface

Direct Submission via Certified Electronic Health Record

Care related to the Quality ID measures will be documented in the EHR and then the data will be extracted by either the practice or a third-party intermediary and submitted to CMS via a special web-based portal. In either case, the EHR must be considered 2015 certified EHR technology (CEHRT).

Qualified Registry Reporting

For registry-based reporting, if reporting as an individual EC, work with your qualified registry to determine what data you need to provide to support submission. If reporting as part of a group practice, find out who within the practice manages registry-based MIPS reporting and how they will handle reporting on your behalf.

Qualified Clinical Data Registry Reporting

RDNs are encouraged to take advantage of a new opportunity to use the Premier Clinician Performance Registry or the U.S. Wound Registry to report new Malnutrition Quality Measures as part of their MIPS reporting. These QCDRs can be used to submit data for Improvement Activities along with Quality measures. Participating as an EC in one of these QCDRs allows RDNs to gain access to benchmark and feedback reports as well as enhance patient care and improve identification of patients at risk for malnutrition. Learn more about how to use one of these QCDRs for your MIPS reporting.

If you use a billing service, check to find out how it will submit Quality measures on your behalf. For example, does the service use claims-based billing or act as a third-party intermediary? Also determine what data you need to provide to the service to support submission.

How will RDNs know if they are submitting Quality measures correctly?

Your NPI number is used to track your performance in MIPS. You will be able to tell if your reporting data has been accepted when you see the remittance advice from Medicare. Remittance advice denial code N620, found on the Explanation of Benefits form, is your indication that the Quality codes are valid.

If you are not getting N620 remittance advice codes, there is a problem with your claims submission. You will need to investigate what might be causing the problem and work to correct it.

Quality Scoring Under MIPS

In the 2021 performance year, Quality accounts for 85% of the final total MIPS Score for RDNs.

Note: RDNs who are ECs and participate in the QPP are scored based on two categories (out of four total). As a result, the weight for the Cost performance and Promoting Interoperability categories is added to the weight for the Quality performance category when calculating the final total MIPS score. See Cost Performance and Interoperability Categories for more information.

ECs can earn up to 60 measurement achievement points in the Quality performance category (earn 3-10 points per Quality measure up to 6 measures). MIPS is scored on a scale of 1 to 100 points, however since the weight of the quality measure is reweighted for RDNs for final scoring, the maximum points this category can contribute to the Final Score in 2021 is 85 points.

Small practices (15 or fewer ECs) are awarded 3 points for submitted quality measures that don’t meet the data completeness requirements.

ECs may also earn Bonus Points:

  • 2 points for outcome measures (after the first required outcome measure is submitted)
  • 1 point for other high-priority measures (after the first required measure is submitted)
  • 6 points small practice bonus for ECs in small practices (15 or fewer ECs) who submit data on at least 1 quality measure.

Improvement Scoring for Quality

ECs may earn up to 10 additional percentage points in their Quality performance category based on their improvement from the previous year. To be eligible, ECs must submit all required measures for at least 70% of their Medicare Part B patients seen during the year. If the EC has a previous Quality performance score less than or equal to 30%, CMS will assume a previous year category score of 30%.

Visit the QPP Resource Library to download the 2021 Quality Quick Start Guide.