As we move into the third performance year of the Quality Payment Program (QPP), CMS is starting to take the training wheels off the Merit-based Incentive Payment System (MIPS). The threshold to avoid a penalty in 2019 doubled to 30 points, and the exceptional performance threshold increased to 75 points (up from 70 points in 2018).
CMS will continue to ratchet up those requirements over the next couple of years, leading up to full implementation of the program in 2022. At that point, the performance threshold will be based on the mean or median of the final scores from a prior period. In the meantime, CMS continues to provide a significant amount of flexibility to ease the transition and reduce the reporting burden.
Here are six things you need to know about the final rule for 2019.
- Payment adjustment jumps to 7%. For the 2019 performance year, CMS is increasing the potential payment adjustment to +/- 7%. That’s a two-percentage-point increase over 2018, after increasing just one percentage point between years one and two.
- New low-volume threshold. In 2018, clinicians were excluded from MIPS if their Medicare Part B charges were less than or equal to $90,000 per year (up from $30,000 per year in the first performance year) or if they provided care to 200 or fewer Part B enrollees (up from 100 enrollees). In 2019, CMS maintained the 2018 thresholds and added a third low-volume criterion: 200 or fewer covered professional services under the Physician Fee Schedule.
- Opt-in option. A new opt-in policy allows clinicians to voluntarily participate if they exceed at least one of the three low-volume thresholds. For clinicians who are providing high-quality care, this is an opportunity to increase 2021 Medicare Part B reimbursements while laying the foundation for future value-based payment programs.
- New types of eligible clinicians. In 2019, more types of professionals are being swept into the MIPS bucket. CMS expanded the list of eligible clinicians (ECs) to include physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists and registered dieticians or nutrition professionals.
- Quality continues to be a priority. Through its Meaningful Measures Initiative, CMS identified the most meaningful measures with the least amount of burden and greatest impact on patient outcomes. Through this initiative, the agency added eight new quality measures and removed 26 measures. The quality performance category will make up 45% of the total score in 2019.
- 2015 Edition CEHRT required. To facilitate patient access to data and sharing of information between healthcare providers, CMS is requiring ECs to use 2015 Edition certified EHR technology in the 2019 performance period.
Steps to Take Now
This month, MIPS ECs receive their first payment adjustments for the 2017 performance year. The vast majority — 91% — of eligible clinicians participated in 2017, and the 2019 performance year is also shaping up to have high participation. CMS projects approximately 798,000 ECs, which is almost 148,000 more than it previously estimated. The final number will depend on the number of ECs excluded from MIPS based on their status as QPs or Partial QPs, the number that report as groups and the number that elect to opt-in to MIPS.
Since it is the nonparticipants and poor performers that fund positive payment adjustments for the strong performers, this high participation rate makes it challenging for clinicians to achieve a significant payment bump. But there are some steps you can take to increase your chances of a positive payment adjustment. To position yourself or your practice at the front of the pack in the 2019 performance year:
- Be mindful of the new types of ECs. If your physician practice, hospital or health system employs physical therapists, nutritionists or other newly eligible professionals, assess whether any of them are being swept into the MIPS bucket. If so, consider how you will capture and report the required data.
- Assess your EHR system. The Promoting Interoperability category makes up 25% of the total score for the 2019 performance year. ECs who don’t have 2015 Edition CEHTR in place won’t get any credit for this category. If you don’t already have one in place, start weighing the costs of implementing an EHR system against other options, such as joining a virtual group. Also keep in mind that practices with 15 or fewer ECs can shift the 25% share of the total score from the Promoting Interoperability category to the Quality category, giving them additional time to implement a CEHRT system.
- Select quality measures carefully. Focus on quality measures that are stretch goals for your practice, instead of choosing low-hanging fruit. CMS is phasing out six quality measures that are “topped out” — in other words, so many clinicians are performing so well in those measures that they do not offer any upside. You’ll get a lot more bang for your buck by investing time and resources in meaningful measures that truly improve the value of patient care.
Most important, take advantage of the flexibility offered by CMS during this transition period to prepare for full implementation of MIPS and other value-based payment programs. Build your skills and your infrastructure now so that when the training wheels come off in 2022, your clinicians will be the exceptional performers who will see the most positive impact on reimbursement.
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