Get ready for MIPS in 2019
In Practice
Faiza Wasif, MPH, is the AAD's practice management manager. Her column offers tips on an area she commonly receives questions about from members.
By Faiza Wasif, MPH, February 1, 2019
CMS has made several changes to the 2019 Merit-based Incentive Payment System (MIPS). While CMS did not finalize any sweeping changes to the program, dermatologists should be aware of changes to MIPS weights and scoring, the low-volume threshold exemption, and other provisions that will impact reporting in 2019. Here are the highlights.
Payment adjustment
The penalty for not participating for 2019 will go up to 7% (up from 5% in 2018) as required by law. See the full program timeline below.
The image above depicts the timeline for the MIPS program outlining the reporting year, the year when incentives/penalties would be applied, and the amount of potential incentive/penalty.
Eligible clinicians
There is also an opportunity to opt-in to MIPS, allowing some clinicians who otherwise would have been excluded under the low-volume threshold the option to participate in MIPS. Eligible clinicians or groups will be able to opt-in if they meet or exceed at least one or two, but not all three, of the low-volume threshold criterion.
Eligibility criteria
The low-volume exemptions are as follows:
- Bill ≤ $90,000 in Part B allowed charges for covered professional services, OR
- Provide care to ≤ 200 Part B enrolled beneficiaries, OR
- Provide ≤ 200 covered professional services under the Physician Fee Schedule
Note: The first two criteria remain the same as 2018, and if you meet any of those criteria you are exempt from participation and will not receive a penalty nor be eligible for an incentive. There are two determination periods CMS assesses to determine if you met these criteria:
- An initial 12-month segment beginning on Oct. 1, 2017, to Sept. 30, 2018; and
- A second 12-month segment beginning on Oct. 1, 2018, to Sept. 30, 2019.
Eligibility can still be confirmed on the QPP website in early 2019 (once it is updated by CMS): https://qpp.cms.gov/participation-lookup/.
Performance thresholds
The thresholds to avoid the penalty or achieve an incentive have changed. The minimum score to avoid the penalty is 30 points, up from 15 points in 2018, and the minimum score to achieve the maximum incentive is 75 points, up from 70 points in 2018.
MIPS in 2019
Avoid the penalty = 30 points
Eligible for maximum incentive = 75 points
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or virtual groups. Note: For the 2019 performance period, the virtual group election period closed on Dec. 31, 2018. In order to participate in MIPS as a virtual group, an election must have been made prior to the start of the performance period and can’t be changed once the performance period begins.
Performance categories
The performance categories remain the same in 2019: Quality, Improvement Activities, Promoting Interoperability (previously Advancing Care Information), and Cost.
However, the weights for two out of the four categories have changed:
- Quality reduced to 45% in 2019 from 50% in 2018
- Cost increased to 15% in 2019 from 10% in 2018
Improvement Activities and Promoting Interoperability remain at 15% and 25% respectively.
Performance periods
- Quality: 12-month calendar year
- Cost: 12-month calendar year
- Promoting Interoperability: 90 days minimum
- Improvement Activities: 90 days minimum
Small practice accommodations
Several accommodations remain for small practices (15 or fewer providers) including:
Claims-based reporting for the Quality category
- 3 points awarded per quality measure just for reporting
- 6 bonus points added to numerator of the Quality category (instead of the 5-point bonus added to the overall MIPS score from 2018)
- Hardship exemption for the Promoting Interoperability category available via an application process at https://qpp.cms.gov/mips/exception-applications.
Extreme and uncontrollable circumstances
CMS will automatically reweight the Quality, Improvement Activities, Promoting Interoperability, and Cost performance categories for MIPS-eligible clinicians who are affected by extreme and uncontrollable circumstances affecting entire regions or locales. To apply, visit https://qpp.cms.gov/mips/exception-applications.
Watch for the full details of the new rule as well as reporting options and interactive tools coming soon to the AADA Practice Management Center at staging.aad.org/macra.
