October 3, 2019 marks the beginning of the gun lap for 2019 MIPS race, the last continuous 90-day period which ends on December 31, 2019. In this race, think of Promoting Interoperability (PI) and Improvement Activities (IA) as the Sprint Events for which 90 days is the minimum reporting period, and Quality and Cost categories as the Marathon Events for which MIPS eligible providers need to report for the entire year. Additionally, the MIPS incline is getting steeper every year.
For 2017, the threshold to avoid the -4% penalty was 3 points. Most eligible clinicians were able to complete that race without breaking a sweat. For 2018, the threshold to avoid the -5% penalty was 15 points. Once again, it took some slight stretching, but the little extra distance was hardly felt. For this year, the threshold to avoid the -7% penalty is 30 points. Now it is getting serious. Most providers will need to cover at least two of the three performance categories that are within their control (Quality, PI, IA) to achieve the 30 points. It will take some planning to succeed in this year’s race.
Four Keys to Winning the MIPS Race
For 2019, understanding the PI objectives, the collection type mix for Quality, the Exceptions you might be eligible for, and being vigilant about Cost are keys to winning the MIPS race. However, there have been some significant changes in the PI and Quality categories for 2019 that warrant extra attention. Let me explain.
1. Understanding PI Objectives and Exceptions
Scoring for the PI category has changed significantly. The PI measures have been restructured. There is a combination of required measures (Security Risk Analysis and Provider to Patient Exchange) with no ability to opt out. Failure to complete these measures will result in a zero PI category score, even with scores in other PI measures. Other PI measures have the ability to either opt out or score bonus points (e-Prescribing). Rounding out the course in PI are the Health Information Exchange measures, which is the reason the category was renamed Promoting Interoperability, followed by a multiple Public Health and Clinical Data Exchange measures.
Navigating the newly revised PI course has been one of the most common reasons that eligible clinicians have been reaching out to us for assistance. We provide the coaching necessary to understand when to opt out, complete the measures or potentially file for Hardship Exceptions. We covered the nuances of the Promoting Interoperability category in this recent blog.
2.Understanding Quality Measure Mix
The Quality category has remained fairly consistent in terms of reporting requirements from 2017 through 2019 with reduction in the category weight (from 60% to 45%) and the increase in data completeness (from 50% to 60%) being the significant changes. The eligible clinicians are still required to submit 6 clinical quality measures, with at least one being an outcome or high-priority measure. There are some special cases that will allow you to submit less that 6 measures and that is one of the features that we offer with our MIPS White Glove Services.
One major change in the Quality category for the 2019 performance year involves the ability to submit the Quality measures by more than one collection type (previously referred to as submission method). In the prior two years you had to pick one submission method for all the quality measures. This year, you can submit some measures through a Registry, some through the EHR, and others through the claims submission method. This change provides the opportunity to maximize your quality score by selecting the Quality measures that are best suited for your scope of practice. If you are struggling with determining the optimum mix of collection types, we can help with that.
Each quality measure has an adjusted benchmark, that can change each year, and requires and analysis to determine if the measure that worked for you last year will still be in play this year. This makes Quality the second most requested category for which clinicians ask for our assistance. Our MIPS White Glove Services provides a complete review of your practice and offers a customized MIPS solution (from measure analysis to submission to CMS), complete with a Book of Evidence for documented retention.
3.Understanding the Exceptions Available
The ability to file for Hardship Exceptions is available for this performance year, as it has been in the past. The deadline for claiming Hardship Exception remains December 31st, 2019. CMS has provided the opportunity to choose from two types of Hardship Exceptions. There is one option that allows you to file for a PI category Hardship Exception. The other exception involves Extreme and Uncontrollable Circumstances. The second exception allows you to opt out of additional MIPS categories and provides for reweighting to other categories. This is the third most common area that we are asked for assistance. We provide the guidance to help in the decision-making process on when to apply for the hardship exceptions and how that will affect the overall MIPS performance, and to allow you to fulfill the strategy for penalty avoidance or maximizing incentives.
4.Being Vigilant about Cost Category
The Cost Category equates to Behind the Scenes Event which is handled by CMS from your administrative claims. If you do not meet the case minimums for the Cost category CMS will reweight the 15 points into the Quality category. CMS will apply the Cost category score to your MIPS composite score, and it will be made available in the July 2020 time-frame.
MIPS White Glove Services
Our MIPS White Glove Services provide MIPS eligible clinicians with the necessary guidance to successfully run the MIPS race and excel in it year over year. Our services include:
Assistance in developing the best MIPS strategy for your practice (for solo practices and large groups)
MIPS analytics to help you achieve the highest score to maximize your incentives with the least amount of effort
Data import from your EHR to avoid manual data entry
MyMipsScore Registry and assistance for submission to CMS
Full MIPS documentation with a Book of Evidence to have available in case of an audit
MIPS preparation for the next year
If you need help with 2019 MIPS and want more information, get in touch with us.