Wednesday, May 15, 2019

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.

Measure ID

New Measures for 2019:
Measure Type
Continuity of Pharmacotherapy for Opioid Use Disorder
High Priority
Average Change in Functional Status Following Lumbar Spine Fusion Surgery
High Priority
Average Change in Functional Status Following Total Knee Replacement Surgery
High Priority
Average Change in Functional Status Following Lumbar Discectomy Laminectomy Surgery
High Priority
Appropriate Use of DXA Scans in Women Under 65 Years Who Do Not Meet the Risk Factor Profile for Osteoporotic Fracture
High Priority
·        None
·        Average Change in Leg Pain Following Lumbar Spine Fusion Surgery
High Priority
Zoster (Shingles) Vaccination

HIV Screening


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. 

Thursday, May 2, 2019

Prepping for 2019 Hospital Quality Reporting

Now that the 2018 reporting year has been wrapped up and submitted, this is a good opportunity to examine what worked and what areas need improvement to ensure a successful 2019 reporting year.

Rear-View Mirror

  • On the Quality Net site, we experienced issues with generating reports and site speed.  Apparently, others had the same issues.  Fortunately, CMS extended the 2018 deadline from February 28 to April 14.
  • To compound the frustration, Quality Net lacks an open forum for support tickets.  MIPS, Cypress, CDA 2.0 and C-CDA and FHIR all have open Jira or Google Groups for support, allowing developers, implementers, and users to comment and ask questions using a transparent process. CMS does not.
  • The support process is tedious and time-consuming.  Undisclosed reporting tool issues created “false alarms” for our calculations and turnaround on support tickets moved slowly.   Nonetheless, we worked with the CMS help desk and technical support to ensure that our CQMsolution calculations matched Quality Net.
  • In spite of these obstacles, our new ‘Submit to DHIT’ button made testing and submitting a much smoother process.   All clients submitted successfully prior to the deadline.


  • 2015 Certified EHR Technology (CEHRT) must be in place during the entire reporting period, although it is permissible for the certification to happen later, as long as it is posted on the ONC CHPL prior to the end of the reporting period. 
  • In case you still have doubts, 2014 Certified software is not acceptable for 2019 reporting.
  • 2019 Promoting Interoperability (formerly Meaningful Use) now has a MIPS-like scoring system, although unlike MIPS, Quality Measures are not part of the scoring.
  • The big challenge for EHR vendors and other suppliers of eCQM software is the transition to Clinical Quality Language (CQL) but, if done correctly, this transition should be transparent to software users.
  • Keep in mind that your CQM results are digested and posted to the Medicare Hospital Compare website.

Opportunities for Success

  • By submitting eCQMs to the IQR program, you will meet PI (MU) requirements for EHR submission.
  • Start running CQM reports early to identify problem areas and home in on CQMs that are best suited to your hospital.
  • In spite of CMS’ new “Meaningful Measures” initiative, the actual eCQMs and reporting period requirements are not changing for 2019:  You still choose a minimum of 4 eCQMs for one self-selected calendar quarter.
  • The overall list of hospital CMS eCQM measures in 2019 will stay the same, except for one adjustment:
    • CMS 55 is discontinued in the IQR program, but will remain in TJC (see below).
  •  For 2020, CMS is proposing to remove the 7 eCQMs (highlighted in blue, below) so you may want to take this into consideration when choosing your 2019 eCQMs:

  • For 2021, CMS is proposing to adopt two new opioid-related eCQMs: 
    • Safe Use of Opioids – Concurrent Prescribing eCQM, and
    • Hospital Harm – Opioid-Related Adverse Events eCQM. 

TJC Submission

  • The big news is that next year Joint Commission ORYX vendors will assist hospitals using their Direct Data Submission Platform (DDSP).  Additional communication regarding the transition is supposed to be released this Spring.
  • 2019 Measure selection was due on 12/31/2018. Hospitals that still need to select can do so by contacting .
  • 2019 Measures: (no changes from 2018), hospitals choose a minimum of 4 measures for 1 quarter.
  • We submitted to ORYX for a number of clients and found that the calculations from our CQMsolution software were consistent with TJC across the board.

We hope this helps with your 2019 reporting process and, as always, welcome your feedback.