On November 1, the Centers for Medicare and Medicaid Services released the 2020 final MIPS rule. Per usual, most of the proposed changes were approved. However, in an unprecedented move by CMS, several proposed changes were not passed. You’ll want to read this….
Here’s the 411 on the changes in the 2020 final MIPS rule and what’s to come in the program:
• CMS has increased the performance threshold to 45 points in 2020 and 60 points in 2021. It is currently 30 points for the 2019 performance year.
Here’s the deal:
The bare minimum to avoid the penalty will no longer be an option for most MIPS participants. If you want to only avoid the 9% penalty in 2020 you will have to do a lot more to bridge the 15 point threshold increase.
Exceptional Performance Threshold
• CMS will increase the exceptional performance threshold to 85 points in 2020 and 85 points again in 2021. It is currently set at 75 points in 2019.
CMS is mandated by law to set the performance thresholds at the mean or median of clinician performance by 2022. What this means is by 2022, the performance threshold must be high enough that 50% of provider payments must include penalties, and 50% of provider payments must include bonuses.
MIPS Category Changes
Cost and Quality Categories
• CMS proposed to drop the quality category from 45% to 40% in 2020, and again to 35% in 2021. Quality will decrease down to 30% in 2022; the cost category will take on the 5% each year, eventually topping out at 30% in 2022, equal to the quality category.
While the cost category must be up to 30% of the overall MIPS score by 2022, CMS opted not to change up category weights for the 2020 performance year. Quality will remain at 45% and cost at 15% of the MIPS final scores for next year.
• Quality data completeness will increase 10% in 2020 – bumping up quality data completeness from 60% to 70% of clinician’s or group’s patients across all payers in the performance year.
So, in order to earn be eligible for a quality measures full potential points (10 for non-topped out measures) you must submit data on at least 70% of your patients. Otherwise, you will receive a maximum of 1 point per quality measure that does not meet data completeness. [Small practices will continue to receive 3 points for measures that do not meet the data completeness requirements.]
CMS finalized all proposed changes to the improvement activity category:
• Improvement activity inventory will change. Expect new measures in 2020, but also expect changes and removals of others.
Your go-to measure since 2017 may be gone in 2020! Be prepared!
• At least 50% of a group must participate in the activity in order to report and earn credit as a group [currently only a single clinician must participate on behalf of the entire group].
In the 2020 final MIPS rule, CMS gave us a break after the big changes in 2019.
Totally New! MVPs
Coming 2021, CMS introduced a new participation framework called MIPS Value Pathways (MVPs). The goal of MVP is to ensure clinicians/groups are finding the MIPS program to be a meaningful and useful effort, rather than a siloed and irrelevant program. Participants would be in a designated MVP based on their specialty or a specific condition, where measures and activities are interrelated and aligned across the 4 MIPS categories.