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Important update on medicare payment rates and MIPS

October 3, 2019

2018 is the second year of transition in the Merit-Based Incentive Payment System (MIPS). If you are required to report data for 2018 and fail to do so, you’ll receive a 5% reduction in Medicare payments in 2020. In fact, unless you are participating in a Medicare Alternative Payment Model, the only way to receive any payment increase between 2019 and 2020 is to score more than 15 points in the MIPS Program. Unlike the first program year, you’ll need to get started early in the year to ensure success. Here are the key changes that will influence your score in 2018:

Low Volume Threshold Increased

If your Medicare allowables totaled less than $90,000 from 9/1/16-8/31/17 OR if you saw less than 200 patients during that timeframe, you are excluded from MIPS. You don’t need to report data, but you also don’t have any opportunity for a pay increase in 2020 unless your group reports MIPS data as a Group.

MIPS Threshold Increased

For the 2018 reporting period, you must earn a final MIPS score of 15 points to avoid a payment reduction in 2020. In 2017, the threshold was just 3 points.

New Help for Small Practices

If you’re in a practice with 15 or fewer MIPS-eligible clinicians, you automatically get 5 points added to your MIPS final score. If you don’t have a certified EHR, you can apply for a hardship exemption from the ACI category due to financial or operational difficulties – apply by December 31, 2018.

Cost Category is Weighted 10%

CMS will calculate two cost measures for each provider based on claims data submitted during 2018. Your performance on each measure will be compared to benchmarks and receive a score from 1-10 points. Even though the cost category had a weight of 0% in 2017, CMS will be releasing each provider’s 2017 results around July. In 2019, the cost category will be weighted at 30% of your final MIPS score. You’ll want to spend time in 2018 understanding the cost measures and how you can impact them in future years.

Quality Category Changes

  • Reporting period for the Quality Category extended from 90 days to full 12 months
  • For each measure, you must report on 60% of the eligible cases based on all patients seen during 2018 (50% in 2017)
  • 6 ‘topped out’ measures are capped at 7 points (vs the normal 0-10 points for each measure): #21, 23 (Perioperative Care), #52 (COPD), #224 (Melanoma), #262 (Breast imaging), #359 (Radiation Exposure)
  • Practices can earn up to 5 additional points in the Quality Category based on how much their Quality Category score improved from 2017-2018
  • Remember that each year some quality measures are removed, and others are added; some have significant changes. Be sure to review the detailed specifications for 2018 for each measure you are reporting.

Advancing Care Information Category Changes

  • The requirement to use a 2015-certified EHR has been delayed until 2019. In 2018, you can use an EHR certified to either 2014 or 2015 standards, but the use of a 2015-certified system will allow you to earn an additional ten bonus points in this category. The 90-day minimum reporting period for this measure was also retained for 2018.
  • If you report to any public health or specialty registry you can earn ten performance points. In 2017, this option was limited to those who reported to immunization registries only. Reporting to a second public health or specialty registry allows you to earn five bonus points.
  • Providers who meet any of the following designations can elect to be exempt from the ACI category, and the 25% weight is reassigned to the Quality category: Hospital-based, Amb Surg Center-based, Non-Patient-Facing.

Improvement Activity Category in 2018

About 20 new improvement activities were added for 2018. None were removed, but some had significant changes. Be sure to review the details and suggested documentation for each measure as it is published by CMS. This category continues to allow a reporting period as short as any consecutive 90 days or as long as the full 12 months of 2018.

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