Changes to MIPS announced in the 2019 QPP Proposed Rule

The MIPS 2019 QPP proposed rule includes several changes to the Merit-Based Incentive Payment System (MIPS) that aim to reduce the administrative burden for eligible clinicians and put more emphasis on the improving EHR interoperability.

In 2017, 91% of MIPS eligible clinicians successfully participated, thus giving CMS the encouragement to continue increasing the program requirements. At the same time, CMS has maintained certain measures of flexibility, particularly for small practices.

Enacted earlier this year, the Bipartisan Budget Act of 2018 provides additional authority to continue the gradual transition in MIPS for three more years, to help further reduce clinician burden.

The 60-day comment period during which CMS will receive public comments and recommendations ends on September 10^th, 2018, with the final rule expected to be published in fall.

Key Highlights from the MIPS 2019 QPP Proposed Rule

MIPS Eligibility

New clinician types proposed are:

1. Physical therapists
2. Occupational therapists
3. Clinical social workers
4. Clinical psychologists

Performance Threshold

1. Performance threshold is proposed to double from 15 to 30 points to avoid negative adjustment.
2. Additional performance threshold is proposed to be set at 80 points for exceptional performance.
3. Similar to the 2018 Final rule, CMS is proposing that clinicians and groups who submit less than two performance categories will not be eligible for incentive payments.
4. The maximum negative payment adjustment is -7%. Positive payment adjustments can be up to 7% (but they are multiplied by a scaling factor to achieve budget neutrality)
5. The additional payment adjustment for exceptional performance shall be applied in the same way as in 2018 for scores at or above the additional performance threshold

Low-Volume Threshold

1. Proposal to include a third criterion for determining MIPS eligibility
2. To be excluded from MIPS, clinicians or groups would need to meet one of the following three criteria:

1. have ≤ $90K in Part B allowed charges for covered professional services, OR
2. provide care to ≤ 200 beneficiaries, OR
3. provide ≤ 200 covered professional services under the Physician Fee Schedule (PFS)

Opt-in

Eligible clinicians who meet one or two criteria (but not all) of the low-volume threshold, will have the choice to participate in MIPS (referred to as the opt-in policy)

Performance Category Weight

1. Cost category weight increases from 10% to 15%
2. Quality category weight decreases from 50% to 45%

Support for Multiple Collection Types for Quality measures

1. A single Quality measure may be submitted via multiple collection types (MIPS CQM, eCQM, QCDR measures, and Medicare Part B Claims measures)
2. The measure will be scored on the data submission with the highest achievement points.

Promoting Interoperability Requirements and New Scoring Methodology

1. 2015 Edition CEHRT becomes mandatory
2. The single measure set based on 2015 Edition CEHRT
3. A new scoring methodology which removes base, performance and bonus scores
4. Introducing Performance-based scoring with each measure scored based on the clinician’s/group’s performance for that measure

Introduction of Facility-based Quality and Cost Performance Categories

1. Facility-based groups and clinicians to be evaluated on the measure set for the Hospital Value-Based Purchasing (VBP) program.
2. Benchmarks for facility-based measurement are those that are adopted under the Hospital VBP program of the facility.

What we think about the possible changes:

In Year 3 of MIPS, the Cost component will be the key to success. Based on the 2017 payment adjustments, most Eligible Clinicians were able to score quite well on the other 3 MIPS categories (Quality, PI, and IAs). If this trend continues, then the true differentiator will be the Cost component. In 2022 the performance threshold will be set to the mean or median performance of all Eligible Clinicians, and that means each Eligible Clinician will have to be better than average in order to not be penalized. If providers don’t keep pace with that average, they will be penalized.