What’s on the horizon for MIPS in 2020?

On July 29, 2019, CMS released its proposed rule for the Quality Payment Program (QPP), including proposed changes to MIPS in 2020 and beyond. The full document is here. Below are some highlights to help you navigate these proposed changes, focusing on the 2020 performance year.

Please note that a final rule will be released later this fall, after a public comment period, in time for the performance year to begin on January 1, 2020.

Performance Threshold Increase

The proposed rule calls for an increase in the performance threshold (minimum number of points to avoid a negative payment adjustment) from 30 points in 2019 to 45 points in 2020.

• Potential +/- 9% adjustment/penalty for not reporting
• Increase the additional performance threshold for exceptional performance to 80 points in 2020

MIPS Performance Category Weights

The proposed rule calls for a reduction in the Quality performance category weight to 40% in 2020. But it also increases the Cost performance category weight to 20% in 2020.

Proposed category weights:

Another increase is in the data completeness requirement, which would increase from 60% to 70% beginning in 2020. Quality measures would need to be reported on at least 70% of eligible cases for 2020. 

Cost Category Proposed Changes

The proposed rule adds 10 new episode-based measures to the Cost category as follows:

1. Acute Kidney Injury Requiring New Inpatient Dialysis
2. Elective Primary Hip Arthroplasty
3. Femoral or Inguinal Hernia Repair
4. Hemodialysis Access Creation
5. Inpatient Chronic Obstructive Pulmonary Disease (COPD) Exacerbation
6. Lower Gastrointestinal Hemorrhage
7. Lumbar Spine Fusion for Degenerative Disease, 1-3 Levels
8. Lumpectomy Partial Mastectomy, Simple Mastectomy
9. Non-Emergent Coronary Artery Bypass Graft (CABG)
10. Renal or Ureteral Stone Surgical Treatment

Cost category proposed changes also include the following attribution changes:

• Total Per Capita Cost - exclude non-primary care service providers
• Medicare Spending Per Beneficiary – clinician attribution changes would have a different methodology for surgical and medical patients

Promoting Interoperability Category Proposed Changes

As stated in the chart above, the Promoting Interoperability (formerly Meaningful Use) category remains at 25 percent weight overall. Proposed changes include:

• Required:  Yes/No for ‘Query of PDMP’
• Redistribute the points for the Support Electronic Referral Loops by Sending Health Information measure to the Provide Patients Access to Their Health Information measure if an exclusion is claimed.
• Special Status:
  • Considered hospital based if more than 75% of NPIs work in hospital-based setting (reduced from 100%)
  • Non-patient facing if more than 75% of NPIs are classified as non-patient facing (reduced from 100%)

Improvement Activities Category Proposed Changes

As stated in the chart above, the Improvement Activities category remains at 15 percent weight overall. Proposed changes include:

• If reporting as a group, at least 50% of clinicians must participate in the activity for the same 90 consecutive day period
• Rural Areas now defined by Federal Office of Rural Health Policy (FORHP) eligible zip code (previously defined by HRSA)
• Patient Relationship Codes (RDC) Modifiers:
  • Voluntary reporting of the codes would count towards the Improvement Activity performance category of MIPS for the 2020 performance year
  • X1 – Continuous/Broad services
  • X2 – Continuous/Focused services
  • X3 – Episodic/Broad services
  • X4 – Episodic/Focused services
  • X5 – Only as Ordered by Another Clinician

If your practice needs assistance navigating the Quality Payment Program, please contact us. Our team of Transformation Support Services experts can help.