What you need to know about MIPS Year Three (Y3)

April 2019 – Vol. 38, No. 3

The Centers for Medicare & Medicaid Services (CMS) implemented extensive updates for Y3 of the Merit-based Incentive Payment System (MIPS). Key programmatic changes for 2019 address eligible clinicians, technology requirements, performance categories, scoring methodology, measures, and objectives, as well as thresholds and bonus points. The items below highlight some of the major changes for Y3 that AAO-HNS members need to know:

1. More MIPS eligible clinicians – Eligible clinicians (ECs) represent the same five provider groups from year two but now also include additional practitioners such as qualified audiologists, clinical physical therapists, occupational therapists, qualified speech-language pathologists, and registered dieticians or nutrition professionals.

The Reg-entSM registry offers 22 specialty-specific measures. To sign up and use Reg-ent for MIPS 2019 reporting, visit www.reg-ent.org.

2. 2015 Certified Electronic Health Records Technology (CEHRT) required – Submission of data in each of the following performance categories now requires 2015 CEHRT: Quality, Improvement Activities, and Promoting Interoperability.

3. Modified performance category weights – The weighting of the Quality category decreased from 50 percent to 45 percent of the final MIPS score, while the Cost category increased to 15 percent. Promoting Interoperability and Improvement Activities categories remain the same (25 percent and 15 percent, respectively).

4. Restructured Promoting Interoperability performance category – This performance category includes the following new elements:

  • Base, performance, and bonus scores were eliminated and replaced with a new scoring methodology (100 total category points);
  • Two new e-prescribing objectives are available; and
  • ECs must meet four objectives: e-prescribing, health information exchange, provider to patient exchange, and public health and clinical data exchange, unless an exclusion is granted. ECs are also required to report certain measures associated with the objectives.

5. New quality measures – CMS added eight new quality measures for 2019 and removed 26 measures that were duplicative or “topped out.”

6. Increased thresholds to avoid penalties and obtain bonus points – ECs and groups must earn at least 30 points (an increase from the 15 points required in 2018) to ensure a neutral payment adjustment. ECs and groups seeking a performance bonus must also earn at least 75 MIPS points (an increase from 70 points in 2018).

7. Modified small practice point system – Small practices (fewer than 15) will still receive a small practice bonus, but, for 2019, the bonus is now reflected in the Quality performance category score instead of as a standalone bonus. If ECs submit data on at least one Quality measure, the bonus points will be increased to six points (as compared to five points in 2018).

8. MIPS Opt-In policy – ECs or groups may opt-in to MIPS if they meet or exceed at least one, but not all three, of the low- volume threshold criteria.

To learn more about 2019 MIPS requirements and access fact sheets and user guides, visit https://qpp.cms.gov/participation-lookup/about.