MIPS 2020 is here. Here are the highlights
Answers 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, April 1, 2020
Each month Dermatology World tackles issues “in practice” for dermatologists. This month Faiza Wasif, MPH, the Academy’s practice management manager, explains MIPS 2020.
Editor's note: In light of the COVID-19 pandemic, CMS continues to monitor the situation and assess potential relief options for MIPS 2020 requirements. When specific guidance becomes available, it will be posted on staging.aad.org/macra.
As anticipated, CMS has made changes to the Merit-based Incentive Payment System (MIPS) for 2020. Below are the highlights to get you prepared for a successful reporting year!
Payment adjustment
The penalty for not participating for 2020 will go up to its maximum of 9% (up 2 percentage points from 2019) as legislated by law. See the full program timeline below.
Eligibility criteria
The low-volume exemptions remain the same as 2019:
Bill ≤ $90K 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
The voluntary opt-in option remains, 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 noted above.
Eligibility can still be confirmed on the QPP website in early 2020 (once updated by CMS) by visiting https://qpp.cms.gov/participation-lookup.
Performance thresholds
The thresholds to avoid the penalty, or achieve an incentive, have increased in 2020. The minimum score to avoid the penalty is 45 points, up from 15 points in 2019, and the minimum score to achieve the maximum incentive is 85 points, up from 75 points previously.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or virtual groups. Note: For the 2020 performance period, the virtual group election should have been made by Dec. 31, 2019. In order to participate in MIPS as a virtual group, an election must be 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 2020, with Quality, Improvement Activities, Promoting Interoperability, and Cost maintaining their weights:
Quality: 45%
Data completeness has gone up from 60% to 70%
Improvement Activities: 25%
Group participation threshold up from one clinician to 50% of clinicians in practice
Promoting Interoperability: 25%
Cost: 15%
Performance periods
The performance periods also remain the same in 2020 as in 2019.
Quality: 12-month calendar year performance period.
Cost: 12-month calendar year performance period.
Promoting Interoperability: Consecutive 90 days minimum performance period.
Improvement Activities: Consecutive 90 days minimum performance period.
Small practice accommodations
All of the 2020 small practice (15 or less physicians) accommodations remain the same:
Claims-based reporting allowed for the Quality category
3 points awarded per quality measure that do not meet the 70% data completeness requirement
6 bonus points added to numerator of Quality category
Hardship exemption for Promoting Interoperability category available typically in fall 2020 via an application process at https://qpp.cms.gov/mips/exception-applications.
Extreme and uncontrollable circumstances
CMS will automatically reweight the Quality, Improvement Activities, Cost, and Promoting Interoperability 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.
| EHR status | Avoiding the 9% penalty (45 points minimum) | Achieving the minimal incentive (46 – 84 points) Typically, incentive is less than 0.5% | Achieving the maximum 9% incentive (average maximum incentive in years past has been significantly less due to regulatory requirements) (85+ points) |
|---|---|---|---|
Without an EHR | Report 4 quality measures that can achieve a maximum of 10 points* each for all eligible encounters between Jan. 1 – Dec. 31, 2020, AND attest to 1 high-weighted improvement activity such as utilizing DataDerm for reporting (for a minimum of 90-consecutive days between Jan. 1 – Dec. 31, 2020) (49.5 points) | Report 5 quality measures that can achieve a maximum of 10 points* each for all eligible encounters for the full year (Jan. 1 – Dec. 31, 2020) AND attest to 1 high-weighted improvement activity such as utilizing DataDerm for reporting (for a minimum of 90-consecutive days between Jan.1 – Dec. 31, 2020) (57 points) | (If applicable) Apply and be approved for an EHR exemption to reweight the PI category to quality (making the quality category 70% of the overall MIPS score) then report 6 quality measures that can achieve a maximum of 10 points for all eligible encounters for the full year (Jan 1 – Dec 31, 2019) AND attest to 1 high-weighted improvement activity such as utilizing DataDerm for reporting (for a minimum of 90-consecutive days between Jan. 1 – Dec. 31, 2020 (85 points) |
With an EHR | Report 3 quality measures that can achieve a maximum of 10 points* each for all eligible encounters between Jan. 1 – Dec. 31, 2020, AND 6 PI measures from each of the 4 objectives for all eligible encounters between Jan. 1 – Dec. 31, 2020 (52 points) | Report 3 quality measures that can achieve a maximum of 10 points* each for all eligible encounters between Jan. 1 – Dec. 31, 2020, AND attest to 1 high-weighted improvement activity such as reporting through DataDerm (for a minimum of 90-consecutive days between Jan, 1-Dec. 31, 2020) AND 6 PI measures from each of the 4 objectives for all eligible encounters between Jan. 1 – Dec. 31, 2020 (67 points) | 6 quality measures that can achieve a maximum of 10 points* each for all eligible encounters for the full year (Jan. 1 – Dec. 31, 2020) AND attest to 1 high-weighted improvement activity such as reporting through DataDerm (for a minimum of 90-consecutive days) AND 6 PI measures from each of the 4 objectives for all eligible encounters between Jan. 1 – Dec. 31, 2020. (85 points) (87 points) |
* Quality measures that can achieve a maximum of 10 points when reporting 100% eligible cases in 2020 include the following: 47 (unless reported via claims; then capped at 7 points), 110, 111, 128 (unless reported via claims; then capped at 7 points), 137, 138, 226, 317, 337, 374, 410, and 431. Watch for full details about the new rule, as well as additional reporting options and interactive tools, coming soon to the AADA Practice Management Center at staging.aad.org/macra.
