The Quality Payment Program has two paths – Merit-based incentive Payment System (MIPS) and the Advanced Payment System (APM), which were implemented in 2017. Other than the providers, the Final Rule includes physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutritional professionals. This inclusion has resulted in changes in how small practices are determined. Just a brief on how MIPS scoring methodology are finalized using the weights for the four MIPS performance categories:
- The Cost category will increase to 15%
- There will be drop in quality category from 50% to 45% of the Final MIPS score
- Improvement Activities will remain same as this year at 15%
- Promoting interoperability (previously advancing care information), weights at 25%:
- The MIPS eligible providers are required by CMS to use 2015 Edition certified EHR technology beginning with the 2019 MIPS performance period.
- The Application Programming Interface (API) functionality has proven to be the major improvement of the 2015 Edition, where it supports patient electronic access to their health information and healthcare providers too.
- The data should be able to move from one patient, or set of patients or subset of patients; is also included in 2015 Edition.
- There is increased interoperability and data exchange in the 2015 Edition as the providers are able to export data by themselves, without any assistance of the vendors.
For 2019, CMS has increased the performance threshold from 15 to 30 points. CMS has also added an opt-in opportunity for the providers who want to participate in MIPS, meeting the low-volume threshold exemption criteria. There will be an increase in exceptional performance threshold from 70 to 75, for 2019. Based on this performance the adjustment for 2021 ranges from -7% to +7%. The CMS is also going to include a new scoring method for a smaller set of objectives, it will also include the performance and bonus methodology that CMS currently uses:
- Each measure would contribute to the MIPS eligible provider’s total promoting interoperability performance category score.
- The scores of each individual measures would be added together to calculate the promoting interoperability performance category score of up to 100 possible points for each MIPS eligible provider.
- If a MIPS eligible providers fail to report on a required measure or claim, the provider would receive a total score of zero.
- Security Risk Analysis is no longer scored as a measure, but remains part of the requirements for the Promoting Interoperability performance category.
For small practices, there will be the continuation of bonus and it will also include the Quality performance category score instead of a stand-alone bonus in 2019. They will continue to receive at least three points for quality measures that do not meet the data completeness requirements. The bonus is increased to 6 points instead of 5 points in 2018; if the provider had submitted data on at least one quality measure.
How to boost your MIPS score?
CMS is going to distribute $500 million in exceptional performance bonuses to providers with the highest MIPS scores. Earning a minimum of 15 MIPS points will ensure the avoidance of any penalties in 2020. However, there are varieties of way MIPS score can be maximized. In addition to reporting multiple MIPS categories, providers can also collect MIPS bonus points.
In order to receive these bonus points, the quality measure must have greater than zero performance which should be reported on 60% of eligible patients for the whole year, and have at least 20 patients reported. Also an additional bonus point can be earned for each quality measure by reporting the usage of Certified Electronic Health Record Technology. The providers can also earn up to 10 points in the quality category based on the rate of improvement compared to the previous year, but full participation in the quality category is required. There is also an additional 5 points that CMS will automatically add for treating complex patients based on the data submitted.
CMS has made important changes to the 2019 Merit-based Incentive Payment System (MIPS) for the Medicare fee schedule. While CMS has not completely finalized the program, the practices should be aware of the changes to MIPS weights and scoring, and low volume threshold exemption.
All these points based on different performance categories can get very complicated. This is where iPatientCare comes in and understands that protecting your future Medicare reimbursements is critical and therefore makes MIPS reporting easy. MIPS specialists at iPatientCare can help you formulate the right strategy for your practice. They will make your practice understand the MIPS scores and can reach reporting goals, no matter what they appear to be.
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