Watching the Waves Roll In
Over the past three years we’ve observed increasing challenges with the constant evolution of MIPS under CMS’s Quality Payment Program (QPP). For many providers, the stringent reporting requirements has proven to be considerably tasking for them and their practices with year 3 under MIPS being of no exception.
After reviewing the final ruling, many clinicians were stunned to see the programs reporting requirements had been completely revolutionized. With the ever-changing guidelines and the multitude of changes in 2019, many clinicians familiar with MIPS are struggling to navigate through the tumultuous waves of change. For many others, having eluded MIPS previously, now find themselves facing uncharted waters as 2019 marks the first year they are considered eligible for reporting and are subject to the storm of MIPS.
The First Wave of Change
Clinicians required to report under MIPS must now achieve a total composite performance score of thirty points or higher to avoid being subject to a seven percent penalty. In addition to the composite performance score change, providers are now being challenged to increase their data completeness for each quality measure reported from a 50% floor to now 60% in order to achieve the maximum point value of ten points per measure. Granted, in 2019 CMS did make the election that certain small practice bonuses would still be applicable however revised their application while other bonuses were eradicated completely. Small group practices, defined as being comprised of fifteen clinicians or less, or solo clinicians are still eligible for the small practice bonus on Quality. The minimum point value said clinicians will receive, despite data completeness performance, is three points per quality measure. These clinicians will be granted an additional six points for their reporting efforts that will be applied exclusively as an enhancement to the quality reporting performance category. In addition, those required to engage in MIPS reporting were also confronted with the expansion eligible clinician types along with the introduction of a third low volume threshold. Within the two determination periods, clinicians are evaluated for MIPS reporting but, either meeting the inclusion criteria requirements or by volunteering to report on their own volition. Their eligibility is determined by: assessing not only their Medicare Part-B allowable charges and patient volume, but now also by the number of Part-B services rendered under their Medicare Part-B Physician Fee Schedule within the reporting period.
The Eye of the Storm
Perhaps the most alarming revision under year three of MIPS was the complete restructuring of the Promoting Interoperability performance category. No longer will clinicians be permitted to make elections between base and performance objective measures or utilize a 2014 certified electronic health record for reporting purposes. The new performance category has been consolidated leaving eligible reporting clinicians having to report under four main objectives that must be captured under a 2015 certified product. Along with having to capture numerator and denominator values for each of the objective measures, clinicians must also attest to having performed the following: Prevention of Information Blocking, ONC Direct Review and having performed a Security Risk Analysis prior to the conclusion of the reporting period. Should any of these attestations be overlooked, clinicians will forfeit all points under the Promoting Interoperability performance category. In the event that clinicians feel they are unable to meet all reporting requirements defined under this performance category, they are permitted to submit a hardship exemption application for CMS’s review. Should the hardship be granted, clinicians will exempt out of reporting Promoting Interoperability for the 2019 performance year and the performance weighting of this category will be reallocated to Quality. This reallocation of the performance weighting will increase the Quality performance category significantly to constitute 70% of the clinician’s global composite score earned. For many, this will impose a greater level of importance being placed around how these clinicians report quality. For some clinicians, this reweight may prompt them to review alternative or additional quality measures to ensure maximum point capture and optimal performance rates.
How to Avoid Capsizing
In light of these changes, clinicians may now be asking, “How do we best prepare”? What changes should be made to ensure reporting success? Do these changes imply that I may be now subject to MIPS reporting? Clinicians can breathe easier knowing they are not alone in trying to navigate the MIPS program. If needing further assistance under year three of MIPS, we encourage that you seek out the informational resources available on the QPP website and get in contact with your reseller, MicroMD. Their team is ready to provide direction and support on reporting under MIPS in 2019.
*Please Note: This article only provides a synoptic review of the MIPS program in 2019 and does not adequately depict the expansive changes observed with the programs reporting guidelines in year three.