Is it worth the trouble to do well in MIPS? Since the launch of the MIPS program, healthcare organizations have struggled with this simple question to decide their degree of commitment to the MIPS program. If you had previously decided it is not worthwhile beyond avoiding penalty, 2019 is the year to reevaluate your decision. This blog will help you understand why.
Let’s start with a simple number - the maximum penalty for 2019 MIPS reporting year is 7%. That is a lot. On the other hand, the maximum bonus for 2019 is estimated to be 4.69%, which is significantly higher than that for 2017 and 2018. The word “estimated” is very important here. You can read more how this estimate is calculated in our MIPS Calculator. The 2019 estimate from CMS is based on some key changes in 2019. This is good news based on how accurate CMS estimates turned out to be for 2017 performance year. However, I do believe that the bonus amounts for the 2019 MIPS reporting year could be even higher than estimated. Let me explain.
MIPS is a budget-neutral program. The bonus amount is based on performance of all MIPS eligible providers. The performance is determined by the MIPS score. The “Promoting Interoperability” category accounts for 25% of that score. This is what replaced the old “Meaningful Use” program and requires a 2015 Edition Certified EHR. Almost all the providers who we worked with in 2017 and 2018 received a perfect score in this category. However, the scoring rules for this category have changed significantly for 2019. The PI category score will be reduced to 0 if you are unable to meet the requirements of any of the required measures under the 4 objectives defined for 2019. We had discussed how the Patient Engagement objective under this category has been completely redefined. The changes to PI combined with the fact that the minimum score required to avoid any penalty has been increased from 15 to 30 points will probably result in more negative payment adjustments. To maintain the budget neutrality, that could increase the maximum estimated bonus amounts beyond the current estimates of 4.69%.
If you are interested in the bonus, rather than just avoiding the penalty under MIPS for 2019, there is more good news. Similar to the PI category, there are also changes to the Quality category. In a previous blog, we had discussed how Quality category score is dependent on more than just the performance rate. In 2019, you can now “mix and match” Quality measures between what used to be called different “Submission Methods”. This new flexibility provides a great opportunity to maximize the Quality score which still carries the highest weight in the calculation of the final MIPS score.
MIPS 2019 Webinar
If you are interested in learning more about these changes, join us at our official launch of the 2019 version of MyMipsScore. We will review all the changes in detail and also demo how MyMipsScore really simplifies navigating through all the MIPS performance categories.