MIPS assesses the performance of clinicians based on four categories: Quality,
Cost, Promoting Interoperability (EHR), and Improvement Activities.
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Quality: 45% of Total Score in Year 3 (2019)
CMS maintained the previous reporting requirements of a minimum of six measures, with at least one outcome measure, if available. If no outcome measure is available, the clinician or group must report one “high-priority measure.” CMS maintained the reporting threshold (or data completeness requirement) for quality measures to 60% of Part B patients if reporting via claims, and 60% of all patients for registry reporting. However, CMS eliminated the claims-based reporting option for large practices. Practices of 15 or fewer are able to continue reporting via claims in 2019. CMS will allow data submission through multiple collection types, such as a combination of claims and registry reporting. For full credit in the category, providers have the potential to earn up to 60 or 70 points, depending on practice size. Practices of 15 or fewer providers must report 6 measures, each with 10 total possible points, while practices of 16 or more providers will also be scored on a claims-based hospital re-admission measure in addition to the 6 reported= measures, each worth 10 possible points. Physicians receive an achievement score on each measure, relative to pre-set performance benchmarks based on 2017 performance. CMS will compare physicians’ and groups’ 2018 Quality category scores to their 2019 category scores and award up to 10 points in the category for improvement.
Cost: 15% of Total Score in Year 3 (2019)
CMS will use its authority to continue to weigh the Cost category at below 30% by increasing the 2019 weight slightly to 15%, up from 10% of the MIPS final score in 2018. In addition, the category will include six episode- based cost measures. CMS will maintain the use of the two existing cost measures Total Per Capita Costs for all attributed beneficiaries and Medicare Spending Per Beneficiary. CMS has delayed implementing improvement scoring in the Cost category for three additional years, as required by the MACRA technical corrections.
Promoting Interoperability (PI): 25% of Total Score in Year 3 (2019)
For 2019, CMS overhauled the requirements and scoring of the PI category. CMS eliminated the previous base and performance score structure and streamlined the category to focus on a single set of measures. CMS reduced the number of objectives to four, which include five required measures and two optional measures for 2019. Participants must report on all required measures or receive zero points for the category. CMS eliminated measures that require patient action and modified the health information exchange measures that require action by other practitioners to make it easier for physicians to complete the measures. The category will be scored out of a possible 100 points, with points for each measure determined by dividing the numerator by the denominator. CMS eliminated bonus points for completing Improvement Activities with CEHRT and is requiring that all participants use 2015 CEHRT.
Improvement Activities: 15% of Total Score in Year 3 (2019)
CMS will continue to allow physicians to select activities from a list of more than 100 options, such as care coordination, beneficiary engagement, and patient safety; and added several more activities in 2019. CMS will again score medium- level activities at 10 points and high-level activities at 20 points. Providers must reach a total of 40 points to receive full credit for this category, either by completing two high-level, four medium-level, or a combination of medium- and high-weighted activities.
The weights for each level are doubled for providers practicing in groups of 15 or fewer Medicare-eligible practitioners (40 points for high-level activities and 20 points for medium level activities). Therefore, small practices must only perform one high- level activity or two medium-level activities for full credit in the category. Improvement Activities must be performed for at least 90 days during the reporting period.
Incentives and Penalties
Based on the MACRA statute, MIPS participants will receive a positive, negative, or neutral payment adjustment based on their final score. The negative adjustment will be capped at 7% in 2021 and 9% in 2022. For
2021, based on 2019 performance, only physicians who score below the 30-point performance threshold will be subject to a penalty. Physicians scoring in the estimated lowest quartile, between 0 and 7.5 points, will receive the full 7% penalty. Depending on overall performance in 2019 by all participants, physicians scoring more than 7.5 points but below the 30-point threshold will receive a penalty less than the full 7%. Under the MACRA statute, physicians with final scores above the threshold will receive positive payment adjustments. The higher performance scores will receive proportionally larger incentive payments up to three times the annual cap for negative payment adjustments each year. Positive incentives are increased or decreased by a scaling factor to achieve budget neutrality with the aggregate application of negative adjustments. Despite the potential to earn up to three times the annual cap on penalties, it is unlikely that participants will earn significant bonuses, due to the budget neutrality requirement. MIPS positive payment adjustments are funded using the penalties collected from low-scoring participants. Since CMS has made it relatively easy to avoid penalties during the MIPS transition years, bonus amounts are predicted to remain modest.
Participants who score above the 75-point exceptional performance threshold will receive an additional bonus. The MACRA statute set aside funds for exceptional performance that are not subject to the MIPS payment adjustment budget neutrality