We’re coming upon the third year of the Quality Payment Program and its MIPS component, and you know what they say—the third time’s the charm. Ready to have your best MIPS year yet? Here’s what the recently-released final rule has in store for eye care providers in MIPS performance year 2019 (and related payment year 2021). Think of it as an early Christmas present 🙂
In the final rule, CMS cemented many of the changes in July’s proposed rule. But first, let’s get a quick vocabulary update out of way. CMS loves to create new names for old concepts, so here are a few new terms to know:
- The Advancing Care Information category—formerly known as Meaningful Use—is now called Promoting Interoperability.
- In the Quality category, “reporting methods” will now be called “collection types.” Collection types include claims, Qualified Clinical Data Registries (like IRIS® and AOA MORE), EHRs, the CMS web interface, and the CAHPS survey.
- Also in the Quality category, what used to be CQMs are now called eCQMs. And “registry measures” will now called MIPS CQMs.
Now, let’s take a look at how MIPS 2019 is continuing to ramp up, get real, and get tougher…
MIPS 2019 participation is expected to reach an all-time high. Part of the reason is that CMS has added eligibility for additional clinician types, including audiologists, dieticians/nutritionists, physical and occupational therapists, clinical psychologists, and midwives. Expansion of clinician types likely will not have a large impact on eye care since eye care practices don’t typically employ those types of clinicians.
Another reason for increased eligibility is that CMS has created a new MIPS opt-in for low volume clinicians, geared mainly to small practices who previously didn’t have a chance to participate. Low-volume clinicians can opt into MIPS if the exceed any one or two (but not all) of the following low-volume thresholds:
- Provide care to more than 200 Part B patients
- Have more than $90,000 in Part B claims
- Provide more than 200 covered professional services (new threshold)
Reporting periods are still variable for performance year 2019 depending on the category. For the Practice Improvement and Promoting Interoperability categories, you must report for 90 days. That way, if you haven’t yet upgraded to 2015 Edition CEHRT—and 2015 Edition CEHRT is mandatory for 2019—you can still do so mid-way through 2019. For the Resource use and Quality categories, you must report for a full year. But remember, cost data is automatically reported via claims, so there is technical no “reporting” that you have to do.
Scoring and Payment Adjustments
The 2019 final rule contains some significant changes to MIPS scoring that will undoubtedly affect your practice’s MIPS 2019 strategy. Most notably, the minimum performance threshold will increase from the current 15 points to 30 points. If your MIPS final score falls below 30 points, you will see the maximum negative payment adjustment on your claims in 2021. By the way, that maximum penalty is increasing to negative seven percent. Fall at or above the threshold and you’ll see a positive adjustment of up to seven percent. While the 30 point threshold is still a relatively low bar, it will continue to increase until approximately 50 percent of participants are above it, and 50 percent are below it, in order to maintain budget neutrality.
Doing really, really well in MIPS will also get more difficult in 2019. The exceptional performance threshold will increase from 70 to 75 points. The maximum bonus incentive for those high performers is also increasing. CMS estimates that it will increase to 4.7 percent. While this is a bit less than what was proposed initially, it’s still a pretty big jump. Remember, CMS maintains an additional, separate pool of bonus funds ($500 million pre-allocated by Congress) available to high performers.
MIPS 2019 Performance Category Updates: What You Should Know
You’ll likely have a more difficult time achieving a perfect score in this category in 2019. Why? There are fewer and more difficult measures, and fewer paths to get to that perfect score of 100. Currently, there are 155 possible points you can earn to get to 100, and you have more leeway in the measures you choose—but in 2019, that won’t be the case.
In addition to confirming the 2015 CEHRT requirement, CMS is emphasizing health information exchange (HIE) participation. As a result, HIE-related measures will carry a greater weight than in 2019 than they do now. So if you’re currently focusing on other, non-HIE measures, you’ll need to shift your focus to the HIE measures to score well in this MIPS category.
In 2019, the Promoting Interoperability category will feature six measures, and you must report all six. If you fail to report any measure (or answer “no” for yes/no measures), you’ll end up with a “zero” for the entire category. The security risk analysis component doesn’t count towards your score, but you are still required to complete it to receive any score whatsoever in this category. However, there are exclusions for each of the six measures. If you use one or more of those exclusions, the scoring will be reweighted for the remaining measures to still allow for 100 possible points.
This category will have a bigger impact on your total MIPS score in 2019 because its percentage of the overall MIPS score is growing. In 2019, Cost will account for 15 percent of your total MIPS score (this is at the expense of the quality category, which will decrease to 45 percent). The maximum points available has increased from 10 to 15. This may end up causing providers some frustration, because it means that if you perform exactly the same in this category in 2019 as you did in 2018, you will leave more points on the table, simply because there are more available.
Two existing core measures (Medicare Spending per Beneficiary and Total per Capita Cost) will stay unchanged, while CMS finalized the eight new episode-based measures from the proposed rule. One of those new measures is “routine cataract removal with IOL implantation.” Be aware that all new measures will be scored immediately beginning in 2019. This is different from the Quality category, where new measures won’t be scored for the first two years.
In this category, bonus points will be more limited and the measures’ benchmarks are getting higher in 2019. CMS has also made some significant changes to the available quality measures as part of the Meaningful Measures Initiative. There are eight new measures. Also, 26 measures have been removed, including two eye care-specific measures:
- Diabetic Retinopathy: Documentation of Presence or Absence of macular Edema and Level of Severity of Retinopathy
- Age-Related Macular Degeneration (AMD): Counseling on Antioxidant Supplement
If you qualify for the small practice bonus, that bonus will now be included in your Quality category score instead of as a standalone bonus. Small practice that report at least one quality measure will receive six points (instead of the current five points).
While you still must report the same number of practice improvement, there will be more to choose from in 2019. CMS added several new improvement activities, including “IA_AHE_7 Comprehensive Eye Exams.” Providers in small or rural practices must still report no more than two medium our one high-weighted activity to get the maximum score in this category. For group practices, only one provider per TIN has to perform the activity for the TIN to receive credit.
What to do now: Perform an analysis of your past MIPS performance and projected performance based on the scoring changes. Determine how your score might be affected if you make no changes to your MIPS 2019 strategy. Then, re-evaluate—and determine if and how you should redistribute— the effort and resources you’re using to maintain or raise your score.