Navigating MIPS 2019 Reporting Requirements
It’s hard to believe that on January 1, 2019, the Merit-Based Incentive Payment Program (MIPS) moves into its third year. New data from the Centers for Medicare & Medicaid Services (CMS) shows that 93% of MIPS-eligible clinicians who participated in MIPS 2017 (Year 1) earned positive payment adjustments and 95% avoided a negative payment adjustment.
On November 1, 2018, CMS released the final 2019 Quality Payment Program (QPP) rule for MIPS Year 3 along with final payment policies, payment rates, and other service provisions to the 2019 Physician Fee Schedule (PFS).
CMS Administrator Seema Verma said the 2019 QPP final rule “finalizes dramatic improvements for clinicians and patients and reflects extensive input from the medical community. Addressing clinician burnout is critical to keeping doctors in the workforce to meet the growing needs of America’s seniors.”
In Year 3, key changes include expanding the definition of MIPS-eligible clinicians (ECs), adding a third element to the low-volume threshold, and allowing ECs who meet or exceed one or two elements of the low-volume threshold to choose if they want to participate in MIPS. ECs participating in MIPS will also be required to use 2015 Edition certified EHR technology (CEHRT).
Curious about what’s changed for the 2019 performance period and how it affects the 2021 payment year? We’ve got you covered with answers to frequently asked questions about MIPS.
What are MACRA, QPP, and MIPS?
MACRA is the Medicare Access and CHIP Reauthorization Act of 2015. MACRA ends the Sustainable Growth Rate (SGR) formula to determine Medicare payments, creates a new framework for rewarding providers based on quality, not quantity, and combines existing quality programs into one incentive program called the Quality Payment Program (QPP).
MIPS is the Quality Payment Program that combines three programs into one program for Medicare ECs: Medicare EHR Incentive Program, Value-Based Payment Modifier (VBM), and the Physician Quality Reporting System (PQRS). A fourth category, Improvement Activities (IA), has been created specifically for MIPS.
There are two participation routes available for optometry and ophthalmology ECs under QPP: MIPS or Advanced Alternative Payment Models (APMs). Almost all eye care ECs will fall under MIPS rather than Advanced APMs. ECs participating in MIPS receive payment adjustments based on performance, while Advanced APMs receive payment for sufficiently participating.
How Can You Check if You’re Included in MIPS?
Check your participation status on the Quality Payment Program website using the QPP Participation Status tool. Enter your 10-digit National Provider Identifier (NPI) number to see if you are included in MIPS.
The Low-Volume Threshold (LVT) is calculated twice for individual clinicians:
- September 1, 2016 through August 31, 2017, and
- September 1, 2017 through August 31, 2018
NOTE: As of December 10, 2018, the QPP website is only reflecting the September 1, 2017 through August 31, 2018 determination period.
Graphic Source: CMS Quality Payment Program
What are the Performance Periods for MIPS 2019?
- MIPS 2019 performance period: January 1, 2019 to December 31, 2019
- Quality and Cost performance categories: 12-month period
- Improvement Activities (IA) and Promoting Interoperability (PI) performance categories: minimum continuous 90-day period
- Deadline for submitting MIPS 2019 data: March 31, 2020
- CMS provides MIPS 2019 reporting performance feedback to ECs: July 2020
- MIPS payment adjustments (positive, negative or neutral) are applied to each claim: starts January 1, 2021
Graphic Source: CMS Quality Payment Program
Can You Participate in MIPS as an Individual, Group, or Both?
If you are eligible to participate in MIPS 2019, you must decide if you will report MIPS data as an individual, group, or both (individual and group). According to CMS, “MIPS-eligible clinicians can report data as an individual and as part of a group under the same Taxpayer Identification Number (TIN).”
For more information on how to report MIPS data, visit the QPP website.
What is the New MIPS 2019 Opt-in Policy?
For those ECs and groups who see a low-volume of Medicare patients in 2019, CMS added an “opt-in to MIPS” provision. ECs and groups can opt-in to QPP if they meet or exceed one or two, but not all three, of the low-volume threshold criteria.
ECs who elect to opt-in to MIPS will be subject to a MIPS payment adjustment. According to CMS, once an EC or group opts in, they can’t withdraw participation for the entire 2019 performance year.
For more information about the new opt-in policy and the voluntary reporting option, refer to the QPP 2019 MIPS Opt-in and Voluntary Reporting Policy Fact Sheet.
What are the 2019 Performance and Low-Volume Thresholds?
Performance Threshold: To avoid a negative payment adjustment, the performance threshold criteria will increase from 15 points to 30 points for MIPS 2019. The exceptional performance threshold will increase from 70 to 75 points.
MIPS payment adjustments (positive, negative or neutral) for the 2021 payment year range from -7% to + (7% x scaling factor). The scaling factor is determined so budget neutrality is achieved.
Low-Volume Threshold (LVT): A third low-volume threshold criterion for MIPS 2019 has been added to determine MIPS eligibility. To qualify for the low-volume threshold, individual ECs and groups are exempt from the MIPS 2019 reporting period if they meet one or more of the following three criteria:
- Bill less than or equal to $90,000 in Medicare Part B allowable charges for covered professional services,
- Provide covered professional services to less than or equal to 200 Medicare Part B beneficiaries, or
- Provide less than or equal to 200 covered professional services under the Medicare Physician Fee Schedule (PFS).
Are There Other Participation Exceptions for MIPS 2019?
According to CMS, clinicians are exempt from MIPS 2019 if they:
- Enroll in Medicare for the first time in 2018,
- Participate in an Advanced APM and are a Qualifying APM Participant (QP), or
- Participate in an Advanced APM and are a Partial QP and do not elect to participate in MIPS
For more information on how you can apply for either the Promoting Interoperability Hardship Exception or the Extreme and Uncontrollable Circumstances Exception, visit the Quality Payment Program website. Applications will close December 31, 2019.
How is MIPS Scored?
MIPS calculates the 100% Composite Performance Score (CPS) based on four performance categories that will affect your future Medicare payments: Quality, Promoting Interoperability (PI), Cost, and Improvement Activities (IA).
Each performance category has different weights per reporting year, and your MIPS 2019 final score is based on all weights added together.
Graphic Source: CMS Quality Payment Program
A final MIPS score will equal the performance threshold when the EC joins an existing TIN in the last three months of the 2019 performance period, and the TIN is not participating in MIPS as a group. If the EC joins a practice that is a new TIN in the final three months of the performance period, the above will also apply.
According to CMS, “If a MIPS EC is scored on fewer than two performance categories, the final scoring policy is the same as Year 2.”
What’s Changing for the MIPS 2019 Performance Categories?
- Decreasing weight of final score to 45% (was 50% in 2018).
- ECs must report EHR electronic clinical quality measures (eCQMs) using a 2015 Edition Certified EHR Technology (CEHRT) to measure the quality of health care provided. MaximEyes EHR is 2015 Edition certified and allows ECs who use the EHR software to meet technology, capability, functionality, and security requirements.
- ECs, groups, and virtual groups can submit measures via multiple “collection types” versus one submission method, which provides flexibility to select the best set of quality measures. Exception: “CMS Web Interface measures cannot be scored with other collection types other than the CMS approved survey vendor measure for CAHPS for MIPS and/or administrative claims measures.”
- Adding 8 new MIPS quality measures that include 4 patient reported outcome measures, 6 high priority measures, and 2 measures on important clinical topics in the Meaningful Measures framework, and removing 26 quality measures.
- Small practices (15 or fewer ECs) can report quality data for covered professional services through Medicare Part B claims submissions.
- Small practice bonus is increasing from 5 points to 6 points in the numerator for the Quality performance category score instead of as a standalone bonus. ECs must submit data on at least one quality measure.
- For more information about quality measures requirements, visit the QPP website.
Promoting Interoperability (formerly Advancing Care Information): 25%
- ECs must use 2015 Edition Certified EHR Technology (CEHRT) to earn points in the Promoting Interoperability (PI) category.
- Scoring is no longer divided into base, performance, and bonus. Scoring is based on the EC’s performance for each measure and added together for a total of 100 possible points. If the EC claims an exclusion for a measure, the points will reallocate to other measures.
- ECs are required to report certain measures from each of the following four objectives (unless an exclusion is claimed): e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange.
- Adding two new optional measures to the e-Prescribing objective: Verify Opioid Treatment Agreement and Query of Prescription Drug Monitoring Program (PDMP)—bonus points are available.
- Removing four measures: View, Download and Transmit; Patient Generated Health Data; Patient-Specific Education; and Secure Messaging.
- Renaming the Provide Patient Access measure to Provide Patient Electronic Access. This measure will be 40% of the Promoting Interoperability (PI) category score and the word “Electronic” is critical. While the new measure doesn’t require the patients to use a patient portal or API, “patients should be able to access their health information on demand.”
- Keeping your patients engaged in their healthcare and using a patient portal that integrates with your eye care software, such as MaximEyes EHR, is a critical part of running a successful optometry and ophthalmology practice.
- For more information about promoting interoperability requirements, visit the QPP website.
- Increasing weight of final score from 10% to 15%.
- Adding 8 new episode-based measures, which includes one eye care measure: Routine Cataract Removal with Intraocular Lens (IOL) Implantation.
- Cost performance percent score will be considered in the 2024 MIPS payment year.
- For more information about cost measures requirements, visit the QPP website.
Improvement Activities: 15%
- Removing criterion for “activities that may be considered for a promoting interoperability” and discontinuing the bonus for promoting interoperability activities.
- Adding a new criterion to the category “include a public health emergency as determined by the Secretary.”
- For more information about improvement activities requirements, visit the QPP website.
“The MIPS assistance First Insight provides to MaximEyes EHR customers is an invaluable service. It’s a huge time saver and stress reliever. First Insight knows exactly what needs to be done and how to do it efficiently.” – Holdrege Family Vision Clinic
What do the New MIPS Terms Mean?
Collection Type: Set of quality measures with comparable specifications and data completeness criteria, including as applicable: electronic clinical quality measures (eCQMs), MIPS clinical quality measures (CQMs), Qualified Data Registry (QCDR) measures, Medicare Part B claims measures, CMS Web Interface measures, CAHPS for MIPS survey measure, and administrative claims measures.
Submitter Type: 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 an activities.
Submission Type: The way a submitter type submits data to CMS, such as direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web Interface. Because CMS collects and calculates administrative data submitted for payment, there is no submission type of cost data.
MIPS Terms Source: CMS Final Rule Overview
QPP, MIPS and PFS Industry Resources
- QPP Website
- QPP Resource Library
- QPP Participation Status Tool
- HCQIS Access Roles and Profile (HARP) – CMS moved to the new HARP system for Enterprise Identity Management (EIDM) credentials
- 2019 MIPS Quick Start Guide (PDF)
- 2019 MIPS Quality Performance Category Fact Sheet (PDF)
- 2019 MIPS Opt-in and Voluntary Reporting Policy Fact Sheet (PDF)
- 2019 QPP Final Rule Executive Summary (PDF)
- 2019 QPP Final Rule (regulatory resource)
- 2019 QPP Other Payer Advanced APMs Fact Sheet (PDF)
- Electronic Clinical Quality Improvement (eCQI Resource Center)
- Quality Measures Requirements
- Promoting Interoperability Requirements
- Cost Measures Requirements
- Improvement Activities Requirements
- 2019 Physician Fee Schedule Fact Sheet
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