On November 1, 2018 CMS released the Final Rule for 2019 that finalized payment and policy changes to the Quality Payment Program starting January 2019.
All clinicians participating in MIPS must be aware of the key continuing and changing Quality Payment Program provisions for Year 3. Some of the changes demand immediate attention to avoid costly penalties.
#1. Additional Eligible Clinicians
CMS added physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dietitians or nutrition professionals to the list of MIPS eligible clinicians.
#2. Opt-In Policy
CMS also finalized an opt-in policy that allows some clinicians who otherwise would have been excluded under the low-volume threshold, the option to participate in MIPS.
#3. Payment Adjustments
Maximum upward adjustments and maximum penalties increased to +/-7%.
#4. Performance Threshold Adjustments
As anticipated, the performance threshold doubled from 15 total score points to 30. This change makes it impossible to avoid a penalty by achieving a maximum score in Clinical Practice Improvement Activities (CPIA) category alone.
#5. Quality Performance Category
- Weight to final score changed to 45%.
- Data Completeness – remains at 60%, with reduced scoring changes if five or less measures reported.
- Reporting mechanisms:
Fundamental change: Claim submission mechanism will be available only for small practices (15 clinicians or less). All other groups must secure an alternative reporting option for 2019 performance year as soon as possible.
#6. Cost Category
Weight to final score changed to 15%. As in previous years, no separate reporting is required; the data is pulled by CMS from administrative claims.
#7. Facility-Based Quality And Cost Scoring For Eligible Clinicians
CMS finalized the option to use facility-based scoring for eligible facility based clinicians who are planning to participate in MIPS as a group. Under this option, the Quality and Cost performance category scores for eligible providers will be based on how well their hospital performs in the Hospital Value Based Purchasing Program (VBP). However, for a number of reasons, some hospitals do not receive a total performance score in a given year in the Hospital VBP program. In these cases facility based clinicians must participate in MIPS via another method.
To help clinicians assess this reporting option, CMS plans to release a facility-based scoring preview in the first quarter of 2019. While this option affords providers a welcome opportunity to reduce the reporting burden, eligibility for facility-based scoring, as well as its’ viability and benefits as an exclusive reporting mechanism must all be carefully evaluated. If utilized, clinicians will still have to attest to performing CPIA or report data in Promoting Interoperability category.
#8. Promoting Interoperability Performance Category (PI)
In an effort to promote, prioritize and emphasize health information technology that enables secure exchange of electronic health information, CMS’s has renamed Advancing Care Information performance category to Promoting Interoperability.
- The Final rule requires that MIPS eligible clinicians use 2015 Edition certified EHR technology beginning with the 2019 MIPS performance period to make it easier for the patients to access their data and to help share patient information between doctors and other health care providers.
- Weight to final score remains at 25%.
#9. Clinical Practice Improvement Activities Performance Category
Weight to final score remains at 15%. CMS added six new Activities, modified five existing Activities and removed one existing Activity.
In conclusion, CMS have effectively removed claims-based reporting as a mechanism for most Emergency Medicine clinician groups. Therefore, it is imperative that any groups not already reporting or confirmed 2019 reporting via an ACO or a registry such as CEDR, make it a priority to finalize and implement their strategy for 2019 MIPS participation to avoid a 7% penalty in 2021 payment year.