MIPS 2019 Final Rule: Key Changes

The QPP 2019 Final Rule was released in November 2018 in which many of the changes in the proposed rule were finalized. The biggest changes are bringing new clinician types under the MIPS fold, making 2015 edition certified EHR a requirement, restructuring of the Promoting Interoperability category, making multiple submission methods available for Quality and Facility-based scoring. It is accompanied by some expected changes like the increase of performance thresholds, redistribution of weight between Quality and Cost categories and some measure adjustments in all performance categories  Let's take a closer look.

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2019 Performance Category Weights

There is shuffling of the performance category weight from the Quality category to the Cost category. CMS approach for future years will be to gradually keep shifting more weight to the Cost category till both the categories have equal weight of 30%.

QUALITY

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PI

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IA

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COST

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Eligibility in 2019

Six new MIPS eligible clinicians have been added to the existing clinician types.

  • Physicians

  • Physician assistant

  • Nurse practitioner

  • Clinical nurse specialist

  • Certified registered nurse anesthetist

  • A group that includes such professionals

New Eligible Clinician Types Added

  • Physical Therapists

  • Occupational Therapists

  • Qualified Speech Language Pathologists

  • Qualified Audiologists

  • Clinical Psychologists

  • Registered Dietitian or Nutrition Professionals

LOW VOLUME THRESHOLD (LVT)

To be included in MIPS in 2019 MIPS performance year, eligible clinicians must satisfy all three components of Low Volume Threshold (LVT):

  1. Bill > $90,000 in Medicare Part B allowed charges AND

  2. Provide care to > 200 Medicare Part B beneficiaries AND

  3. Provide >200 Covered Professional Services (new for 2019)

ELIGIBILITY DETERMINATION PERIOD

For 2019, a single set of determination periods that align with the fiscal year will be used for all clinicians including small practices, ASC-based, hospital-based, and non-patient facing clinicians.

  • 1st Determination Period: Oct. 1, 2017 to Sept. 30, 2018

  • 2nd Determination Period: Oct. 1, 2018 to Sept. 30, 2019

To be MIPS eligible, the clinicians need to exceed Low Volume Threshold in both of the two 12-month long determination periods. Eligibility status for the first 2019 determination period is available on the QPP Participation Status tool.

OPTION TO OPT-IN 

In 2019, the eligible clinicians who meet or exceed at least one of  the three above-mentioned thresholds, will have the option to participate in MIPS if they choose to. If they do participate in MIPS, they will be subject to MIPS payment adjustment (positive, neutral, or negative). The clinicians who fail to exceed even one LVT criteria, will be excluded from MIPS and will not be able to opt in.

Read about the Opt-In option

2019 Payment Adjustment Calculation

Performance Threshold increased to 30 points (15 points for 2018) and the Exceptional Performance Threshold increased to 75 points (70 points for 2018). Based on these thresholds, MIPS participants can earn two types of payment adjustments:

Budget Neutral Payment Adjustment 

(MIPS Score 0 - 100)

-7% to +7% of the allowed Medicare Part-B charges

Exceptional Payment Adjustment 

(MIPS Score 75 - 100)

Budget-Neutral payment adjustment

+

0.5% - 10% of allowed Medicare Part-B charges

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Base Payment Adjustment Range:  +/-  7%

For MIPS Score 0 to 7.5 Points: Full penalty of -7% is applicable. Maximum penalty determined for the performance year applies if the score is at or below ¼th of the Performance Threshold for that year (30 x ¼ = 7.5).

For MIPS Score 7.51 – 29.99 Points: Negative payment adjustment gradually decreasing on a linear sliding scale from -7% to < 0% will apply

For MIPS Score of 30 Points: Payment adjustment of 0% at the Performance Threshold of 30.

For MIPS Score 30.01 – 74.99 Points: Providers will receive the budget-neutral component of positive payment adjustment which is scaled from 0% to 7% to provide maximum adjustment of 7% at MIPS score of 100. A scaling factor (up to a max of 3) will be used to equitably distribute every single cent of the penalties collected.

For MIPS Score 75 – 100 Points: Budget-Neutral + Exceptional Performance Payment Adjustment The providers whose score lie in this range will not only earn the budget-neutral payment adjustment, but will also earn an additional exceptional performance positive payment adjustment. This bonus will be given out from $500 million annual budget starting at +0.5% for MIPS score of 75, up to a max of +10% for a MIPS score of 100. Another scaling factor will be utilized to ensure a fair distribution of the exceptional performance incentives, i.e. more money for a higher score and stay within the annual budget of $500 million.
Read: How MIPS Calculators Work?

Multiple Collection Types Can be Used for Quality Measures

Submission Methods and the Reporting Options have been renamed to match the MIPS data submission experience of the eligible clinicians : 

  1. Collection Types: a set of quality measures with comparable specifications and data completeness criteria. These are eCQMs, MIPS CQMs, QCDR measures, CAHPS for MIPS survey, and CMS Web Interface measures. Registry measures have been renamed as MIPS CQMs. In 2019, clinicians can now submit the required Quality measures using multiple collection types. The measure combination that yields the highest score would be considered.

  2. Submission Types: the mechanism by which a submitter type submits data to CMS including Direct, log in and upload, log in and attest, Medicare Part B claims and the CMS Web Interface. CMS now uses HCQIS Access Roles and Profile (HARP) system for credentials management instead of the EIDM used previously.

  3. Submitter Types: MIPS eligible clinician, group (and virtual group), or via a third-party intermediary acting on behalf of clinician or group that submits data on measures and activities under MIPS.

 Changes to Bonus Points

BONUSES RETAINED

CEHRT Bonus for End-to-End Reporting (10% of max Quality Score)

High Priority Bonus (10% of max Quality Score)

Complex Patient Bonus

BONUSES EDITED/ADDED

Small Practice Bonus has been altered. Now 6 points will be added to the Quality category.

(Change from 5 points added to the total MIPS score for 2018)

10 Bonus points added for PDMP and Verifying Opioid Treatment Agreement under the PI category

BONUSES REMOVED

2015 EHR Certified Edition Bonus for PI category no longer available.

No bonus under PI for reporting the Improvement Activities via EHR .

No bonus points for reporting to an additional Clinical Data Registry under PI category.

High Priority Bonus in the Quality category has been removed for CMS Web Interface reporters.

Flexibility and Bonuses for Small Practices

  • Claims Option for Small Groups: Medicare Part B Claims will be available to Small Practice Groups (1-15 eligible clinicians) for submitting MIPS data.

  • Small Practice Bonus moved to the Quality Performance Category: 6 points will now be added to the numerator while calculating the Quality performance category score (instead of being added to the MIPS score).

  • Double Points for IA: Small practices earn double the points for Improvement Activities performance category

  • Data Completeness Not Met: Small practices will receive 3 points even if data completeness falls below 60% for Quality measures that do have a benchmark and meet the case minimum requirement. The other clinicians will receive only 1 point.

Promoting Interoperability Category Restructured

Promoting Interoperability (PI) category has undergone a complete restructuring for 2019. All the changes proposed for PI in 2019 have been finalized. The 2015 Edition EHR is required by the end of the 90-day reporting period.

The measures have been divided under 4 objectives:

  1. ePrescribing

  2. Health Information Exchange

  3. Provider to Patient Exchange

  4. Public Health and Clinical Data Exchange

Each objective is required. You must report on all the required measures across all the objectives or claim an exclusion (when applicable) to earn any score in the PI category. If exclusion is claimed for certain measures, points are redistributed to the other measures/objectives. This is new for 2019. Like previous years, Security Risk Analysis (SRA) is a requirement without which no score can be earned in the PI category.

Facility-Based Scoring Available

This is a new scoring option that is available in 2019 to the facility-based MIPS eligible clinicians and groups for the Quality and Cost performance categories. The 2019 measure set for Hospital Value-Based Purchasing (VBP) program will be used for scoring. These clinicians will still need to submit the data for PI and IA categories for their MIPS score. It’s noteworthy that the facility-based clinicians CAN submit the data for Quality measures along with IA and PI data. If they do, the data that yields the highest MIPS score for the clinicians will be used. We will discuss facility-based scoring in detail in a subsequent blog.

In the light of all the changes, it is vital for organizations big and small with MIPS eligible clinicians to monitor their MIPS performance to stay ahead of the game, especially the newly eligible clinicians. MyMipsScore can help you with your 2019 MIPS strategy.

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