High Overview of changes to the MIPS 2019 Program

CMS released the 2019 Quality Payment Program Final Rule early November 2018.  Below are highlights of some of the key provisions for Year 3 (2019) of the QPP MIPS program that will go into effect 1/1/19. These are overall changes to the program in 2019.

Changes to the MIPS performance threshold and the exceptional performance bonus:

  • The MIPS performance threshold will double in 2019. MIPS eligible clinicians and groups will have to earn at least a total of 30 MIPS points (up from 15 points in 2018) to ensure a neutral payment adjustment. It will be very important to understand all the categories and criteria in order to meet this new threshold.
  • Clinicians and groups seeking an exceptional performance bonus will need to earn at least 75 MIPS points (up from 70 points in 2018).

2019 Payment adjustments:

The payment adjustments for 2019 will range from -7% up to 7% in the 2021 payment year. Any positive payment adjustments will be multiplied by a scaling factor to ensure budget neutrality.

New Clinician types added:

In addition to Physicians, PAs, NPs, CNS, and CRNAs the following clinicians will be eligible to report in 2019:

  • Physical, occupational therapists
  • Speech-language pathologists
  • Audiologists
  • Clinical psychologists
  • Registered dietitians or nutrition professionals

2019 Category weights for 2019:

  • Quality will be worth 45% of your total MIPS score in 2019 (down from 50% in 2018)
  • Cost category will increase to 15%
  • Promoting Interoperability will remain the same in 2019 at 25% of your total MIPS score
  • Improvement Activities weight will remain the same this year at 15%.

New criteria for low-volume threshold

Third criterion for clinicians to qualify for the low-volume threshold. Clinicians and groups must meet one of the following three criteria to be excluded from MIPS:

  • Have $90,000 or less in Part B allowed charges for covered professional services; OR
  • Provide care to 200 or fewer beneficiaries; OR
  • New: Provide 200 or fewer covered professional services under the Physician Fee Schedule (PFS). If eligible clinicians meet one or two elements of the low-volume threshold they will have a choice to participate in MIPS, (opt-in).

Some other highlights:

Continued assistance for small practices (15 or fewer eligible clinicians billing under the same TIN)

  • CMS is Increasing the small practice bonus to 6 points, but including it in the Quality performance category score of clinicians in small practices instead of as a standalone bonus
  • Continuing to award small practices 3 points for submitted quality measures that don’t meet the data completeness requirements
  • Allowing small practices to continue submitting quality data for covered professional services through the Medicare Part B claims submission type for the Quality performance category
  • Providing an application-based reweighting option for the Promoting Interoperability performance category for clinicians in small practices
  • Continuing to provide small practices with the option to participate in MIPS as a virtual group
  • Offering a no-cost, customized support to small and rural practices through the Small, Underserved, and Rural Support (SURS) technical assistance initiative.

You’ll also notice the use of new terms being introduced this year:

  • Collection Type-
    • Electronic clinical quality measures (eCQMs)
    • MIPS clinical quality measures (CQMs) (formerly “Registry measures”)
    • Qualified Clinical Data Registry (QCDR) measures
    • Medicare Part B claims measures
    • CMS Web Interface measures
    • The CAHPS for MIPS survey measure
    • Administrative claims measures.
  • Submitter Type- the MIPS eligible clinician, group, or third party intermediary acting on behalf of a MIPS eligible clinician or group, as applicable, that submits data on measures and activities.
  • Submission Type – the mechanism by which the submitter type submits data to CMS, including, as applicable: direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web Interface. There is no submission type for cost data because the data is collected and calculated by CMS from administrative claims data submitted for payment.

Please check back with Meridian Medical Management for a breakdown of changes for each MIPS category for 2019 if applicable.