Final 2022 MIPS Submission Report Overview

Your final 2022 MIPS Group and Individual submission data have been compiled corresponding to your Organization's Tax Identification Number(s) (TIN) and for each provider’s individual National Provider Identifier (NPI) associated with the TIN. This data will be submitted to CMS pending certification of your reporting type. Please note, individual patient data is not submitted to CMS as part of this process. The final 2022 MIPS submission data should be reviewed carefully to confirm your reporting type and your intent for Keet Health to submit your MIPS data to CMS on your behalf for the 2022 MIPS performance year. 

To finalize your 2022 MIPS submission, review the final 2022 Group and Individual MIPS submission data published within the Keet Submission Dashboard located within QuickSight. Once complete, submit the 2022 MIPS Submission Attestation Form to certify your reporting type and intent for Keet Health to submit your MIPS data to CMS.

Note

The information in the MIPS submission dashboard may vary from what is in the Keet Outcomes Dashboard v3.1. due to how exclusion populations are applied in the final submission. Additionally, EOCs without an assigned supervising provider will not be included in Individual submissions because an NPI must be associated to each EOC for this reporting type. Because Group or Group + Individual submissions include these EOCs there may be discrepancies in the dashboard submission totals relative to those EOCs that are being included with group versus individual.

Report Components & Definitions 

Submission Summary Report

Use the Submission Summary report to assess performance for MIPS submission.

Please note: only the providers who have consented to individual submission will be included in the individual sections of this report.

Total measures for each TIN/Practitioner that outperform the Keet Avg RA FTP

Displays the number of MIPS measures where the TIN's/practictioner's Risk-Adjusted Average FTP rate was lower (positive performance) than the Keet Avg RA FTP rate. Additional columns indicate if the Keet Avg RA FTP rate was outperformed by 0-4.9%, 5-10%, or >10%.

Submission List & Submission List Detail Overview
Displays final submission populations at the Reporting Type level. If Reporting Type is set to Group, you will see the aggregate data for each measure under each TIN you have for submission. If Reporting Type is set to Individual, you will see the individual performance by measure per NPI for each practitioner that has provided consent to participate. The Submission List Detail provides additional information about the cases that make up each measure's population for the "group" reporting type.
Submission List
In the Submission List table, there are populations you are used to seeing in the Keet Outcomes Dashboard and additional columns added to help you assess and measure performance. These will help you determine what measures are outperforming the Keet average, and by how much. While the Keet average is not interchangeable with the CMS-generated benchmark, it will help you assess how your organization performed in comparison to the average keet client. As a reminder, the case minimum must be met, indicated by a blue Y before performance can be assessed. 
Performance Met/Performance Not Met Populations
The Keet IROMS measures are Inverse measures. The MIPS quality measures offered by Keet Outcomes QCDR define performance met or performance not met based on the measure(s) being collected.  The Keet Outcomes IROMS measures (IROMS 11, 12, 13, 14, 16, 17, 18, 19, 20, and KEET01) are inverse measures.  As defined by CMS, “in an inverse measure, a lower calculated performance rate for this measure indicates better clinical care or control. The ‘Performance Not Met’ numerator option for this measure is the representation of the better clinical quality or control.”  

Unlike the IROMS measures, the Dizziness Handicap Inventory (DHI) outcome measure is not an inverse measure, therefore the ‘Performance Met’ numerator option for this measure is the representation of better clinical quality or control. In other words, the DHI displays the percentage of patients who have progressed rather than those that have failed to progress. See the table below for how this translates to the Keet Outcomes Dashboard.  

 


IROMS Quality Measures

Submission Dashboard Name KOD Name Meaning
Performance_Met FTP Population Cases that did not meet or exceed the MCID.
Performance_Not_Met Progressed Population Cases that met or exceeded the MCID.

DHI Quality Measure

Submission Dashboard Name KOD Name

Meaning

Performance_Met Progressed Population Cases that did meet or exceed the MCID.
Performance_Not_Met FTP Population Cases that did NOT meet or exceed the MCID.
Submission List Detail - Contains EOCs for the ' ' reporting type
The submission list detail table includes the individual cases that are part of one or more reporting populations for the CMS quality measures. While individual patient-level detail is not submitted to CMS, this is included for you to be able to view the patients in each aggregate population. In addition to the recognizable column fields, we have added a column "included in submission" to indicate whether that EOC was included in the final performance rate submission calculation or is part of the exclusion or exception criteria. You may use the control "EOCs included in submission" to surface only those that are part of the final submission performance rate, or those that are removed. Note that when viewing submission list detail with the "GROUP" Reporting Type control selected, all providers will be listed as NULL as providers are not identified in GROUP level submission.
submission_list_detail_group.png

Submission Summary All Strata Report

In the final submission, Keet Outcomes QCDR provides multiple groupings of your quality performance data to CMS. CMS uses the risk-adjusted overall strata for final scoring as surfaced in the submission summary tab. Additionally, Keet has provided you all submission strata for optional review. This is displayed under the submission summary, all strata report. Below are two similar tables that display the measure specification populations for each of the IROMS quality measures of the 6 CMS reported strata, and the DHI quality measure for the 4 CMS reported strata. A Strata is a grouping of patients according to particular CMS-defined criteria.

 

IROMS Quality Measures Strata

Strata Treatment Definition
Observed NonOp MCID The proportion of [conservative] patients not achieving an MCID.
Observed Operative MCID The proportion of [surgical] patients not achieving an MCID.
Observed Not Achieving Overall proportion of patients not achieving an MCID.
Risk-Adjusted NonOpRisk A risk-adjusted MCID proportional difference will be reported where the difference between the risk model-predicted and observed MCID proportion will be reported.
Risk-Adjusted OpRisk A risk-adjusted MCID proportional difference will be reported where the difference between the risk model-predicted and observed MCID proportion will be reported.
Risk-Adjusted Overall A risk-adjusted MCID proportional difference will be reported where the difference between the risk model-predicted and observed MCID proportion will be reported.

 

DHI Strata

Strata: Criteria:

Submission Age Criteria 1

Patients aged 14-17 years of age
Submission Age Criteria 2 Patients aged 18-64 years of age
Submission Age Criteria 3 Patients aged 65 years and older
Submission Age Criteria 4 Overall total rate of patients aged 14 years and older

 

2022 Final MIPS Submission Data Review FAQs

How is scoring impacted if the 70% Compliance Rate or 20 Case Minimum requirement is not met?

Outlined below are the 3 scenarios used to calculate the scoring for each outcome measure. Note that for 2022, if you have not met the case minimum on 6 out of 10 measures, you may be at risk of a negative payment adjustment. 

For additional information on scoring, refer to the QPP Traditional MIPS Scoring Guide. 

Scenario by Measure Description Scoring Rules Per Measure
1

The measure can be scored based on performance.

The measure meets all of the following criteria:
(1) Has a benchmark;
(2) Has at least 20 cases; and
(3) Meets the 70% data completeness requirement

Scenario 1 measures will be awarded 0 to 10 points based on performance compared with the benchmark. 

2 The measure does not meet the 70% data completeness requirement.

Scenario 2 measures will be awarded 0 points, except for small practices, which will receive 3 points.

 

3 The measure meets the 70% data completeness requirement but does not have at least 20 cases.

Scenario 3 measures will be awarded 3 points.

 

Do these reports include the CMS benchmark I will be graded against?

No, Medicare will calculate the benchmark for 2022 after all data has been submitted. 

 

Why are there only 6 PRO measures by TIN and Individual NPI

The IROMS PRO measure is actually listed twice: once for the PROM measure and again for the corresponding PRO numeric pain scale rating (NPRS).  You may need to scroll within the Performance Report to view the pain measures.

  • KOS - IROMS 11
  • KOS NPRS - IROMS 12
  • LEFS- IROMS 13
  • LEFS NPRS- IROMS 14
  • NDI- IROMS 15
  • NDI NPRS- IROMS 16
  • MDQ- IROMS 17
  • MDQ NPRS- IROMS 18
  • DASH- IROMS 19
  • DASH NPRS- IROMS 20
  • DHI/HM07 

What Improvement Activities are reported? 

Keet helps you achieve the maximum available points for the Improvement Activities category by satisfying and reporting on the following measures:

  • IA_BE_6: Collection and follow-up on patient experience and satisfaction data on beneficiary engagement
  • IA_BE_7: Participation in a QCDR, that promotes use of patient engagement tools
  • IA_BE_8: Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive
  • IA_BE_22: Improved Practices that Engage Patients Pre-Visit
  • IA_AHE_3: Promote Use of Patient-Reported Outcome Tools

Can Keet review my data to tell me how to report or assess my performance?

No, we cannot advise on specific performance or decisions other than to offer the guidance and process requirements documented by CMS. For more information on how MIPS Quality Measures are scored, CMS has provided the 2022 MIPS Scoring Guide.

The dashboards display separate rows for IROMS measures related to the same region of injury, one for function and the other for pain. However, each row shows both the function and pain scores. Is this how it is supposed to display?

Yes, the IROMS functional and pain measures related to the same region of injury will display scores for both pain and function in each row. This relates to how the information is captured in our surveys and is presented this way for those who want to view the pain and function scores together.