2019 is the third performance year of the Merit-Based Incentive Payment System (MIPS). While many of the requirements for 2019 are the same as they were for the 2017 and 2018 performance years, there are a few key changes ophthalmology practices should be aware of to be successful in the program. This guide outlines key changes for 2019. For other resources, visit www.qpp.cms.gov..

MIPS Performance Threshold
  • The 2019 MIPS performance threshold is 30 points, increased from 15 points in 2018. Physicians and practices must score at least 30 total points to avoid a 7% penalty in 2021.
Cost Category
  • Cost will count for 15% of a physician’s final MIPS score in 2019, up from 10% in 2019.
  • The category now includes several episode-based cost measures, including one for cataract surgery.
  • Physicians and groups do not need to submit any data for this category. CMS will calculate the score based on administrative claims.
Promoting Interoperability Category
  • Following ASCRS and medical community advocacy, CMS made a major overhaul of this category that streamlines and simplifies the requirements and scoring. Participants must report on a single set of required measures. Measures requiring patient action have been removed, and health information exchange measures have been modified.
  • All participants must use only 2015-edition certified EHR technology (CEHRT) in 2019.
Small Practice Accommodations
  • CMS instituted several policies to help practices of 15 or fewer Medicare-eligible providers succeed in MIPS, such as:
    • Promoting Interoperability Hardship Exemption – apply to re-weight the 25% weight to the Quality category.
    • Small practice bonus – 6 points added to the Quality category score.
    • Continued scoring flexibility in the Quality and Improvement Activities categories.
Low-Volume Threshold
  • CMS maintained the threshold of $90,000 in allowed Part B charges or 200 patients and added 200 or fewer Medicare professional services. Physicians who exceed one or two, but not all three, criteria may opt into MIPS for 2019. Practices in areas with high participation in Medicare Advantage may be excluded from MIPS.
Quality Reporting
  • Quality reporting via Medicare Part B claims is no longer an option for large practices of 16 or more Medicare-eligible clinicians.
  • Small practices of 15 or fewer may now report as a group through claims but must submit the other categories of MIPS as a group for CMS to score claims data collectively.
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