The Centers for Medicare and Medicaid Services (CMS) issued its Final Rule for the Quality Payment Program (QPP) on Friday, November 1, 2019, resulting in changes to the Merit-based Incentive Payment System (MIPS) in 2020 and future reporting years. The Final Rule continues to gradually increase the reporting requirements under the MIPS program. The QPP, established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), is currently in its third year.
How will it affect your practice? Key highlights for Year 4 include:
1. Scoring. CMS increased the minimum number of points eligible clinicians and groups must receive to avoid a negative payment adjustment. In 2020, the performance threshold will be 45 points, up from 30 points. Additionally, the exceptional performance threshold to achieve a bonus will increase from 75 to 85 MIPS points.
|Additionally, for eligible clinicians who choose not to report, there will be greater financial implications. The maximum penalty for not reporting will rise to -9% on Medicare Part-B payments (up from -7% this year). While payment adjustments would range from -9% to +9%, any positive payment adjustments are expected to be below 9% due to the federal budget neutrality requirements.|
2. Category weights. The MIPS reporting requirements and category weights remain the same in 2020:
|Quality||Cost||Promoting Interoperability||Improvement Activities|
3. Quality category. Specific to the quality performance category, CMS increased the data completeness requirements from 60% to 70% in MIPS 2020. This means Quality measures will need to be reported on at least 70% of eligible cases, for both Medicare and non-Medicare patients, throughout the year. Reported measures that fall below this threshold will receive 0 points (except for small practices with 15 or fewer clinicians under the group’s Tax Identification Number, or TIN, that will continue to receive 3 points). Clinicians who are able to submit more than 70% of eligible data are required to do so.
4. Promoting Interoperability category. CMS finalized changes to the threshold for a hospital-based group, requiring that more than 75% of the clinicians in the group are hospital-based MIPS eligible clinicians, down from 100% in 2019. That designation means that the group is exempt from reporting any measures in the Promoting Interoperability (PI) category. Their PI weight reduces to 0%, while their quality category weight increases to 60%.
5. Improvement activities category. Starting in MIPS 2020, groups earn credit for an improvement activity if at least 50% of clinicians fulfill the activity during a continuous 90-day period within the performance year. In previous years, groups earned credit for an improvement activity if at least one clinician fulfilled the activity. For MIPS 2020, the 50% of clinicians fulfilling the activity do not have to fulfill the activity during the same 90-day period.
6. Cost category. CMS will add 10 new episode-based measures to the Cost category and revise the current measures – Medicare Spending Per Beneficiary Clinician measure and Total Per Capita Cost measure. There will be no changes to current case minimum requirements.
7. Who is eligible. CMS did not propose any changes to eligibility or to the definition of a MIPS eligible clinician for the 2020 performance period. To be eligible for MIPS, the low-volume threshold remains at $90,000 of Medicare Part B charges or 200 Part B-enrolled beneficiaries, or 200 or fewer covered professional services to Part B-enrolled individuals. Any clinician who exceeds all three criteria will be required to participate in MIPS, while any clinician who falls below the threshold for any of the three criteria will be excluded from MIPS participation and may be eligible to opt-in or voluntarily report. Visit the reporting options overview for more information.
8. EHR certification. CMS did not propose any changes to this requirement for 2020. Clinicians continue to need to use the 2015 Edition certified EHR technology for those actively participating in the Promoting Interoperability performance category and to report electronic clinical quality measures (eCQMs) for the Quality performance category.
Preparing for what’s ahead
MIPS eligible clinicians and groups should continue to stay on top of their 2019 MIPS data reporting and become familiar with the changes for the 2020 reporting year. Reporting and planning are necessary to avoid any penalties. Now is the time to determine how to refine your reporting strategies throughout 2020 and maximize your score in preparation for 2021.
Below are some additional things to consider when looking toward the future:
MIPS 2021. CMS will begin to transition MIPS to a new conceptual framework, called MIPS Value Pathways (MVPs) beginning with the 2021 performance year. MVPs will change the reporting and methodologies on the current measures of Quality, Cost, Promoting Interoperability, and Improvement Activities. Instead, clinicians will report on a reduced set of clinical and specialty-related measurement sets relevant to their practice that are outcome-based and more closely aligned to Alternative Payment Models (APMs).
MIPS 2022. MACRA requires CMS to weigh the cost category at the same weight as the quality category starting in MIPS 2022, which means both categories will then be weighted at 30% of the MIPS composite score.
For more information, visit the CMS QPP resource library.
Quanum™ Electronic Health Record (EHR) by Quest Diagnostics is fully certified to meet CMS regulatory requirements and is prepared to support your practice. Learn more by calling 1.888.835.3409 or email SalesSupport@Quanum.com.
Curious about the Year 3 Final Rule? Watch the on demand session now of our Quest Diagnostics sponsored webinar with CMS, QPP – Understanding the CMS final rule. For more information on MACRA, view our training video.