A Closer Look At The MIPS Changes For 2019

The year 2019 is the third year of the Centers for Medicare and Medicaid (CMS) Merit Based Inventive Payment System (MIPS). The system continues to evolve and there are significant changes for 2019. These include:

• Threshold to avoid a penalty raised to 30 MIPS points.
• Exceptional performer threshold raised to 75 MIPS points.
• There are new eligible clinician types for the MIPS, including physical therapists. This is noteworthy for those who work in the same group as or employ physical therapists.
• For a low volume participation exemption to MIPS, clinicians or groups now need to meet one or more of three criteria.
• Eligible clinicians who meet one or two elements of the low-volume threshold now have the choice to opt in to MIPS participation.
• For those who qualify, the small practice bonus has decreased as it has shifted from MIPS points added to the final score to points added to the numerator of the Quality performance category.
• If a MIPS-eligible clinician joins an existing practice in the final three months of the performance period year and the practice is not participating in MIPS as a group, that clinician will have a 2019 MIPS score of 30.
• If a MIPS-eligible clinician joins a newly formed practice in the final three months of the performance period year, that clinician will have a 2019 MIPS score of 30.
• In the Quality category, the term “reporting mechanism” changed to “collection type.”
• Clinicians can now submit quality measures via a combination of collection types.
• There is now a single set of measures in the Promoting Interoperability category.
• Clinicians must use 2015 certified electronic health record technology (CEHRT) for the Promoting Interoperability category.
• Base, performance and bonus scores have been eliminated from the Promoting Interoperability category and scoring will now be at the individual measure level.
• Scores for each Promoting Interoperability measure will be added together to calculate the category score.
• The Quality category is now worth 45 percent of the total MIPS score.
• The Cost category is now worth 15 percent of the total MIPS score.

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA’s Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman

References

1. Federal Register. Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; Medicaid Promoting Interoperability Program; Quality Payment Program-Extreme and Uncontrollable Circumstance Policy for the 2019 MIPS Payment Year; Provisions From the Medicare Shared Savings Program-Accountable Care Organizations-Pathways to Success; and Expanding the Use of Telehealth Services for the Treatment of Opioid Use Disorder Under the Substance Use-Disorder Prevention That Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act. Available at https://www.federalregister.gov/documents/2018/11/23/2018-24170/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions . Published Nov. 23, 2018.

2. Federal Register. Public Inspection Issue. Available at https://www.federalregister.gov/public-inspection/current .

3. Centers for Medicare and Medicaid Services. Fact sheet on the CY 2019 Quality Payment Program final rule. Available at

https://www.cms.gov/Medicare/Quality-Payment-Program/Quality-Payment-Program.html .