2019 MIPS – What You Need to Know

You’ve completed 2018 MIPS – everything is submitted and
filed away.  Time to relax? 

Well you certainly deserve some R&R but
don’t lose sight of the upcoming MIPS challenges and opportunities for 2019
reporting year.  Increasingly, MIPS
success will mean a year-round focus as CMS ratchets down on scoring thresholds
and imposes greater penalties for weak and non-performers.  Here is our roundup of changes that will
present challenges and opportunities in the upcoming year.

·      By June of 2019, CMS will have digested and
posted MIPS scores in a patient-friendly format on the Medicare
Physician Compare website. 
The site will have a new hyperlink indicating “Performance information
available”.   This “Performance
information” is derived from MIPS scoring and may be used not just by patients
and prospective patients but by any other interested parties.  So, even though your practice may provide
excellent patient care, a sub-standard MIPS score could drag you down.

·       
Strong performers can submit both as group and
individual and then choose the highest score.  Eligible Clinicians now include Physical therapist, Occupational therapists, Qualified speech-language pathologists, Qualified audiologists, Clinical Psychologists, and Registered dieticians/nutrition professionals. 

·       
eCQMs, Promoting Interoperability
and Improvement Activities (details below) can now all be submitted via the new
QPP API, eliminating the old manual upload process. 

·       
2015
Certified software must be in place during the entire reporting period,
although it is permissible for the certification to happen after the start of
the reporting period, as long as it is prior to the end of the reporting
period. 2014 Certified software is no longer acceptable for 2019 reporting. 

·       
To
avoid a penalty, the minimum score is 30 points as opposed to 15 points in 2018.
Likewise, the exceptional performance bonus threshold is up from 70 points to
75 points.

·       
The
4 categories from 2018 remain but some percentages have been adjusted  for 2019:

1.      Quality 45% (decrease of 5%)

·       
Minimum
of 6 measures for 1 year

·       
1
must be an outcome or High Priority Measures (awarded higher points)

·       
Bonus
points awarded if you choose the same measure and show improvement from 2018

·       
Avoid
topped out measures, since scoring is capped at a maximum of 7 points

·       
On
the overall list of Quality Measures, 26 were removed and 8 were added 8 (6 of
which are high priority — see chart below)

·       
Of
the 26 and 8, some eCQMs changed:

o   CMS 249 and CMS 349 have been
added

o   CMS 65, CMS 123, CMS 158, CMS
164, CMS 167, CMS 169 were removed

o   CMS166 -previously for
Medicaid-only submission – has been phased out.

·       
New
for 2019: CMS will aggregate eCQMs collected through multiple collection types;
if the same measure is collected, the greatest number of measure achievement points
will be awarded.

2.      Promoting Interoperability
25%

·       
Minimum
of 90 days

·       
Only
one set of objectives & measures (reduced from 2 in 2018)

·       
4
Objectives include: e-Prescribing, Health Info Exchange, Provider to Patient
Exchange and Public Health & Clinical Data Exchange

·       
50
point “base value”/bonus from 2018 has been removed

3.      Improvement Activities 15%

·       
Minimum
of 90 days

·       
Added
6, Modified 5, removed 1 = 118 total Improvement Activities

·       
Bonus
removed

4.      Cost 15% (increase of 5%)

·       
1
year

·       
No
actual submission

·       
Groups
must register by June 30.

·       
Submission
Deadline:  March 31, 2020

The bottom line (in our opinion):  Don’t wait until the year is over to take
action to improve your MIPS score. 
Remember, the bar is set higher for 2019 and the financial incentives
and penalties are also greater.