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As we are moving through through year 2 of the MIPS program, it is imperative that eligible clinicians simultaneously prepare for the next few years and the prospective changes to come. With the release of the proposed rule for 2019, participants can get a sense of the impending challenges of the MIPS program moving forward; we can expect most of the proposal finalized this fall. In an effort to simplify the material, we have narrowed down the proposal into (what we believe) are the top three items clinicians and practice administrators should be aware of at this time.

Eagle’s Top Three:

1. Performance Thresholds
One under-reported event is the establishment of a three-year “transition” period for the MIPS program – 2017, 2018 and 2019.  The transition period is designed to give providers a multi-year period to adjust to the MIPS requirements.  In year 1, eligible clinicians needed to beat a “performance threshold” of only 3 points to avoid a 4% penalty. The threshold was increased to 15 points this year, which is still very easy to attain. In 2019, CMS proposes a further gradual increase of the performance threshold 30. So for 2019, additional efforts will be required to avoid the penalty (which will be a whopping -7% reduction in Medicare reimbursement) and obtain an incentive. Participants looking for the big payouts will have to devote serious time and effort to rise above and beyond the 80-point “exceptional performance threshold” for 2019.

2. Eligible Clinicians
Expanded CMS has proposed to include more categories of clinicians into the MIPS eligibility for 2019. ‘Eligible clinicians’ could now include: physical therapists, occupational therapists, clinical social workers, and clinical psychologists. CMS has also added a third criterion to the determination of MIPS eligibility. Under a new ‘opt-in’ policy, clinicians could choose to participate in the program if they meet or exceed at least one (but not all) of the following criteria:

    • $90k in Part B allowed charges
    • 200 beneficiaries
    • 200 covered professional services*

*The addition of this third criterion could potentially extend MIPS participation to over 100,000 more clinicians in 2019, giving them the opportunity to ‘opt-in’ to the program.

3. PI Category
The Promoting Interoperability (formerly Advancing Care Information) category is slated to become much more difficult in 2019. The use of 2015 CEHRT will be required to avoid a score of 0; this in itself is a requirement of the proposal, but it is also necessary for execution of the category’s highly technical performance measures. Among these are new health information and clinical data exchange measures. It will be challenging to obtain a decent score in this category without serious effort.

The MIPS program has been in effect since January 1, 2017. There has been little reporting regarding the enactment of the Bipartisan Budget Act earlier this year in which Congress specified a roadmap for the next few years and when they can expect to see the promised incentives in full.

With the passage of the Bipartisan Budget Act, Congress granted three additional years to the implementation-stages of the program, expanding the ‘transition’ period through performance year 2021, with each year becoming increasingly difficult. Effective 2022, MIPS participants will be expected to be in near-perfect condition across the board in order to avoid penalties and reap the benefits (all the benefits) of the program.

Eagle Consulting urges that you use this transition period to hone your MIPS strategy while CMS is feeling generous. “We strive to implement the program as Congress intended while focusing on simplification and burden reduction, drawing on the flexibilities offered by the recent enactment of the Bipartisan Budget Act of 2018, smoothing the transition where possible, and offering targeted educational resources of the program participants.”-CMS

Take advantage of these transition years by perfecting your MIPS strategy now with the assistance of Eagle’s MIPS Navigator services! Come 2022, will 9% be your penalty or your reward?

Reference: CMS, “Proposed Rule for the Quality Payment Program Year 3

About Alex Dighero


Alex is a consultant and account manager for MIPS-related matters, including pathology sales support, MIPS services sales, and delivery of MIPS services. She is a certified compliance technician with the American Association of Healthcare Administrative Management. She has an MBA in health care administration from Cleveland State University.

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