On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released the 2019 Quality Payment Program (QPP), Final Rule. As of January 1, 2019, the changes will go into effect. According to CMS, the updates for Year 3 are reflective of the feedback they received from stakeholders. Below are the key updates for MIPS Year 3 that you need to be aware of.
1. The performance threshold increased to 30 points for 2019, instead of 15 in 2018. Additionally, the exceptional performance threshold has increased to 75 points.
2. The payment adjustment for the performance year 2019 / payment year 2021 range from -7% to +7%. It's important to note that the positive adjustment factor is multiplied by a scaling factor which could result in an adjustment above (not likely) or below 7%.
3. MIPS eligible clinicians have been updated to include:
Physical therapists
Occupational therapists
Clinical psychologists
Qualified speech-language pathologists
Qualified audiologists
Registered dieticians or nutrition professionals
Tip: remember to check their NPI on CMS's QPP Participation Status Tool.
4. Low volume threshold has been updated. In 2019, there is a third criterion that has been added:
Have $90K in Part B allowed charges for covered professional services,
Provide care to 200 Part B enrolled beneficiaries, OR
Provide 200 covered professional services under the Physician Fee Schedule (PFS.)
5. Clinicians or groups will be able to "opt-in" to participate in MIPS if they meet at least one of the low-volume threshold criteria:
Important: once you choose to opt-in, you cannot change your mind to not participate for the applicable reporting period.
Performance periods for 2019 are as follows:
Quality: 12-month calendar year performance period.
Cost: 12-month calendar year performance period.
Promoting Interoperability: 90 days minimum
Improvement Activities: 90 days minimum
6. The quality category will be 45% of the final score (was 50% in 2018). A single measure can now be submitted to CMS by multiple methods (e.g., claims, QCDR, etc.); however, the score will be provided based on the data submission with the greatest number of measure achievements. The quality category also has a new quality measure that has been added and several that have been removed.
7. Cost category will be 15% of the final score (was 10% in 2018). One update to the cost category you need be aware of is CMS will include the Medicare Spending Per Beneficiary (MSPP) and total per capita cost measures to calculate the cost performance score for the 2019 performance period. This is based on;
A case minimum of 35 for MSPB.
A case minimum of 20 for the total per capita cost measure.
Additionally, Episode-Based Measures such as Knee Arthroplasty (procedural) will be added to list of Cost measure for 2019.
8. Promoting Interoperability (PI) category will be 25% of the final score for the 2019 performance period (minimum of 90 days). Eligible clinicians will be required to use 2015 Edition of Certified Electronic Health Record Technology (CEHRT) in order to report on the PI category. PI scores will be based on performance. There are four objectives that must be met: e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange unless an exclusion applies.
Important: there have been some opinions shared stating that performing or reviewing a Security Risk Analysis will not be required in 2019. This is false! A Security Risk Analysis is still a required measure. The only difference is it is a measure that does not have points.
9.Improvement Activities category makes up 15% or final score. The key update for 2019 is the new improvement activities that have been added, including; Comprehensive Eye Exams; Financial Navigation Program; Completion of Collaborative Care Management Training Program; Relationship-Centered Communication; Patient Medication Risk Education; Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support
10. CMS estimates that just over 91% of eligible clinicians who participate in MIPS will either receive a positive or neutral payment adjustment. CMS also estimates the highest possible positive adjustment a clinician could earn is 1.88 while the lowest is -4%.
Did you know for the MIPS 2018 performance period it's not too late to submit your SRA? To ensure it is reviewed your SRA should be submitted no later than December 15, 2018.
