MIPS 2020 Final Rule
The Centers for Medicare and Medicaid Services (CMS) 2020 Merit-based Incentive Payment System (MIPS) program Final Rule was made available back in 2019. It features several changes to MIPS in 2020 and in future reporting years and continues to gradually increase the reporting requirements. Below, I will share the most relevant changes that will impact your 2020 MIPS performance and help you to plan for the future.
Performance Thresholds and Penalties
For 2020, CMS increased the performance threshold to 45 MIPS points in 2020 (up from 30 points in 2019). This threshold indicates the number of MIPS points needed in order to avoid any penalties. In addition, the exceptional performance threshold increased from 75 MIPS points in 2019 to 85 MIPS points in 2020 and 2021.
The penalties have also increased for providers who choose not to report. The maximum penalty for not reporting MIPS 2020 will rise to 9% (up from 7% in 2019). That means that, should providers opt out of reporting, they could lose up to 9% of their reimbursement from Medicare. On the other hand, if you do perform well, there will be positive payment adjustments. While CMS indicated up to a 9% positive payment adjustment, it will likely be less due to the budget neutrality requirements.
Performance Categories
For 2020, the MIPS category weights remain the same as they were in 2019.
- Quality – 45%
- Promoting Interoperability – 25%
- Improvement Activities – 15%
- Cost – 15%
Quality
For the quality category, the data completeness requirements will increase from 60% to 70% for 2020. This means that at least 70% of eligible cases will need to be reported on each quality measure for the entire year. Measures that are submitted that do not meet this threshold will receive 0 points. Clinicians in small practice (several of my clients qualify for this exception) will continue to receive 3 points for measures that do not meet data completeness requirements.
Additional Changes
- Several measures were removed or topped out
- There were new specialty sets added, including Audiology, Chiropractic Medicine, Clinical Social Work, Endocrinology, Nutrition/Dietician, Pulmonology and Speech Language Pathology.
- A flat, percentage-based benchmark will be applied to certain quality measures to avoid incentivizing inappropriate treatment.
Promoting Interoperability (PI)
There were not any significant changes for the Promoting Interoperability category for performance year 2020. The main updates concerned the following:
- A group is considered hospital-based and eligible for re-weighting if more than 75% of clinicians in the group meet the definition of a hospital-based, MIPS eligible individual.
- CMS will remove the Verify Opioid Treatment Agreement measure and keep Query of PDMP as an optional measure.
Improvement Activities (IA)
Overall, there was a net reduction in the number of IA measures.
- 15 activities were removed, 2 added and 7 modified.
- CMS increased participation threshold for group reporting from a single provider to 50% of providers in the practice.
- The definition of a rural area was modified to mean a zip code designated as rural by the Federal Office of Rural Health Policy using the most recent FORHP file available.
Cost
This category saw the most change for 2020.
- CMS revised the current measures – Medicare Spending per Beneficiary Clinician and Total Per Capita Cost. This is to address the concern from specialty clinicians that patients were attributed to them over who they have minimal control – both behaviorally and clinically. This previous attribution model negatively impacted the cost score of specialists.
- 10 new episode-based measures have been introduced, bringing the number to 18.
Big Changes for 2021 – MIPS Value Pathways (MVP)
With feedback from clinicians and stakeholders that MIPS remains overly complex, the program is adopting an entirely new approach. This framework, beginning in performance year 2021, is called MIPS Value Pathways (MVPs). Under this new participation model, clinicians would report on a smaller set of measures that are specialty-specific and outcome based. It moves away from siloed activities and measures and towards an aligned set of measure options more relevant to each clinician’s scope of practice. It is a significant shift in the way clinicians currently participate.
Infographic Credit: Quality Payment Program
Prima Healthcare Solutions is prepared to help your practice navigate these changing waters with confidence. Give us a call or click the button below and let us know how we can help!