How does MIPS change in 2019?
The CMS decision to delay its momentous E/M coding changes to 2021 have rightly garnered most of the attention since the agency released its 2019 Medicare Physician Fee Schedule (PFS) final rule, but the document also includes changes to its Merit-based Incentive Payment System (MIPS).
CMS will finalize most of the proposed provisions, many of which are statutorily mandated by the 2015 Medicare Access and CHIP Reauthorization Act (MACRA) which established MIPS. The finalized changes for 2019 include the addition of multiple eligible clinician types, including physical and occupational therapists, qualified speech-language pathologists, audiologists, clinical psychologists, and registered dietitian or nutritional counseling professionals. Other MIPS provisions finalized include:
- Minimum performance threshold to avoid a negative adjustment doubles from a 15-point MIPS composite score to 30 points in 2019. The exceptional performance threshold (for which additional bonus monies are paid) increases from 70 points to 75 points – this is actually down from 80 points in the proposed rule.
- Adding a third criterion for MIPS exemption (meaning the provider does not need to report MIPS or comply with any of its requirements, though they will also not be able to earn bonus payments). The third criterion allows providers who provide 200 or fewer covered professional services over a 12-month period to be exempt.
- Allowing non-eligible clinicians or groups to opt-in to MIPS if they meet or exceed at least one, but not all three of the low-volume threshold criteria.
- The MIPS Quality performance category is reweighted from 50% of the MIPS composite score in 2018 to 45% in 2019. Meanwhile the MIPS Cost performance category is reweighted from 10% in 2018 to 15% in 2019. The other performance categories have the same score weights in 2019.
- All participating MIPS clinicians must use 2015 Edition Certified EHR Technology in 2019. Previously either 2014 or 2015 Edition CEHRT was acceptable, with a bonus for those using 2015 Edition CEHRT.
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