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.

 

Opportunities

·      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. 

Challenges

·        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	eCQM ID	New Measures for 2019: Name	Measure Type
468	None	Continuity of Pharmacotherapy for Opioid Use Disorder	High Priority
469	None	Average Change in Functional Status Following Lumbar Spine Fusion Surgery	High Priority
470	None	Average Change in Functional Status Following Total Knee Replacement Surgery	High Priority
471	None	Average Change in Functional Status Following Lumbar Discectomy Laminectomy Surgery	High Priority
472	CMS249v1	Appropriate Use of DXA Scans in Women Under 65 Years Who Do Not Meet the Risk Factor Profile for Osteoporotic Fracture	High Priority
473	·        None	·        Average Change in Leg Pain Following Lumbar Spine Fusion Surgery	High Priority
474	None	Zoster (Shingles) Vaccination	Process
475	CMS349v1	HIV Screening	Process

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

Deadlines

·        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.