The Centers for Medicare & Medicaid Services (CMS) has submitted its annual proposed rule for comment from stakeholders and the public for the 2019 MIPS performance year (PY). This period covers Jan. 1, 2019–Dec. 31, 2019. The proposed rule continues the transition process away from a fee-for-service model to a value-based model until full implementation in 2020.
Increasing Performance Thresholds
Since the first transition year in MIPS, the CMS continues to increase both the performance and additional performance thresholds annually.
The performance threshold is the points a provider/practice must score to avoid a negative payment adjustment and qualify for a neutral payment adjustment. CMS established a 15-point performance threshold in the 2018 PY and is proposing a 30-point threshold for 2019. The most significant impact of the increase in the performance threshold will be on providers who still have not transitioned to an electronic health record (EHR). It will become increasingly difficult to achieve a neutral payment adjustment for these providers because the program continues to increase in difficulty. The higher the score above the performance threshold, the greater the positive payment adjustment.
In 2018, the additional payment adjustment for exceptional performance is for scores that are 70 points or higher. The amount of the adjustment is also applied on a linear scale so clinicians with higher scores receive a higher adjustment. The 2019 proposed rule increases this threshold to 80 points. Under this policy, higher performing providers would most likely receive more substantial payments because fewer providers are receiving these additional payments.
3 MIPS Proposals That Impact Private Practice
Three particular policies will affect private and, more particularly, small practices the most.
1. Recalculating small practice bonus:In 2018, CMS added a five-point small practice bonus to the final score of all practices with 15 providers or less. With a maximum total score of 100 points, this bonus increased a practice’s score by 5%. The 2019 proposal states the following:
“The small practice bonus will now be added to the Quality performance category, rather than in the MIPS final score calculation. Add 3 points in the numerator of the Quality performance category for MIPS eligible clinicians in small practices who submit data on at least one quality measure.”
This would reduce the positive impact of the bonus from 5% (2018) to 1.35% (2019) to the overall final score. The 2018 application of the small practice bonus was very helpful to these providers who do not have the same resources as other large practices or hospitals who have more to spend on MIPS compliance.
Check if your practice qualifies for the small practice bonus in 2018 via the CMS’s NPI look-up tool here.
2. The increasing weight of the Cost category:The 2019 proposed rule continues the importance of cost in the MIPS final score at the expense of the Quality category. The current 2018 performance year has Cost at 10% and the Quality category at 50%. The 2019 proposed rule would reduce Quality to 45% and increase Cost to 15% of a provider’s final MIPS score. This proposal would continue the final score weighting from a category (Quality) that providers have total control over to a category (Cost) that providers have almost no power over. to a category (Cost) that providers have almost no power over. Although high drug costs will be counted in the cost measure, MIPS adjustments will not be applied to the high sums of Part B drug infusions—as a result of pressure by many advocates including the ACR.
3. Mandating 2015 Edition of Certified Electronic Health Record Technology (CERHT): The 2019 proposed rule will no longer allow for the use of 2014 CERHT technology. The current 2018 PY allowed for the use of 2014 CERHT but gave a 10% bonus to practices who utilized 2015 CERHT.
The impact on providers who do not currently use 2014 CERHT would mean they could not accrue any of the 25 points dedicated to this category. Practices would still be able to meet or exceed the proposed 30-point performance threshold, the maximum possible score they could achieve in categories that are in their control would be 60 points (45 from quality + 15 from Improvement Activities). They could achieve anywhere between zero and 15 additional points in the cost category for a maximum score of 75.
Comments Due to CMS in Mid-September
The ACR will comment all on policies in the 2019 MIPS proposed rule. A copy of the comment letter the ACR submits to CMS will be here. All providers are encouraged to submit letters to CMS as well and explain the adverse impact these proposals will have on their practice and patient care.
To ensure you are prepared for MIPS in 2018 and all future years, rheumatology providers should join the ACR’s RISE Registry. Every member who completed a full submission via the RISE Registry in 2017 qualified for financial incentives. Moreover, a significant number of these providers received a perfect score and qualified for the largest bonuses.
Ready for MIPS
To ensure you are prepared for MIPS in 2018 and all future years, rheumatology providers should join the ACR’s RISE Registry. Every member who completed a full submission via the RISE Registry in 2017 qualified for financial incentives. Moreover, a significant number of these providers received a perfect score and qualified for the largest bonuses.
To find out more about RISE or if you have any questions regarding MIPS reporting, you can contact ACR Registry staff at 404-365-1388 or [email protected].
