MIPS in 2019: Changes are coming

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MIPS in 2019: Changes are coming

CMS has made several changes to the 2019 Merit-based Incentive Payment System (MIPS) as part of the final 2019 Medicare physician fee schedule. While CMS did not finalize any sweeping changes to the program, physicians should be aware of changes to MIPS weights and scoring, the low-volume threshold exemption, and other provisions that will impact reporting in 2019.

Changes to MIPS performance weights and scoring

CMS has announced that the minimum score necessary to avoid a penalty in 2021 (reporting in 2019) is 30 points — this is twice the 2018 threshold of 15 points. The minimum required number of points to be eligible for the exceptional score bonus is 75.

CMS also finalized its proposal to reduce the weight of the Quality category from 50% to 45% and increase the Cost category from 10% to 15%. The AADA opposed increasing the Cost category and decreasing the Quality category — recommending that the weights for all categories remain the same in 2019 as it is in 2018 — as the Cost category does not accurately assess the impact of a physician’s care on the total cost of care. Improvement Activities remain at 15% and Promoting Interoperability (formerly known as Advancing Care Information) stays at 25%.

Tweaks to the MIPS low-volume threshold exemption

CMS added an opt-in opportunity for physicians and providers who want to participate in MIPS but meet the low-volume threshold exemption criteria.

If a MIPS-eligible clinician meets or exceeds one, but not all, of the low-volume threshold exemption criteria — as defined by dollar amount ($90,000), beneficiary count (200), or covered professional services to Part-B enrolled individuals (minimum threshold of 200) — then the clinician may elect to submit data and opt-in to MIPS.

If a clinician does not meet at least one of these low-volume determinations — or meets at least one, but not all, of these low volume determinations and elects not to opt-in — the clinician is not eligible and is excluded from MIPS.

The AADA supported these changes.

Small practice accommodations in MIPS

It will be more challenging for small practices in 2019 to avoid a penalty, because CMS is doubling the threshold to avoid a penalty from 15 to 30. However, CMS has finalized the following accommodations for small practices:

  • Small practices may use Medicare Part B claims for reporting quality. All others must report electronically.

  • Small practices will be awarded 3 points per measure for quality measure reporting that does not meet data completeness requirements. Others receive 1 point per incomplete measure.

  • A hardship exception is still available for the PI category via an application process, with score redistribution to the quality category if an exemption is approved.

  • Some small practices may be exempt from the cost category if they do not provide the plurality of primary care services for at least 20 Medicare patients during the performance year. If so, with the exemption from PI and Cost categories, the Quality category will be 85% of the MIPS score. Improvement activities remain at 15%.

  • Six bonus points will be added to the numerator of quality category, instead of three points, per the proposed fee schedule. (In 2018, five points were added to the total score. The AADA advocated that the points be added to the total score, rather than an increase in the quality category.)

QCDR quality measure sharing requirement

In the 2019 proposed fee schedule, CMS outlined a new provision that would require a Qualified Clinical Data Registry (QCDR) to agree to enter a license agreement with CMS that would allow any approved QCDR to submit data on the QCDR measure. If the QCDR refused to enter such a license agreement, the QCDR measure would be rejected and another QCDR measure of similar clinical concept or topic would be approved in its place.

The AADA strongly objected to this requirement and as a result, CMS did not finalize this proposal. Instead, CMS is retaining its current policy that requires a QCDR to seek permission in order to use owned measures within the MIPS program.

The AADA has also advocated that CMS award points for participation in a QCDR such as DataDerm™. However, CMS did not grant this request.

Discontinued ICD-10 codes – Impact on measure reporting

During the 2018 MIPS performance period, the measures that are significantly impacted by ICD-10 updates, as determined by CMS, will be assessed based only on the first nine months of the 12-month performance period.

The AADA is currently advocating for a change in this policy, arguing that CMS should not hold practices accountable for changes to measures based on ICD-10 changes. CMS should score these measures as if they meet case minimums. By not accepting three months of reporting data from the 12-month performance period, practices may not meet case minimums which will affect MIPS scoring.