MIPS FAQs

Data completeness rules for performance year 2019/payment year 2021 state that a provider must submit at least 60% of eligible cases to potentially earn the maximum amount of points per quality measure. CMS has noted their intent to increase the data completeness threshold in future program years but has yet to specify a timeline. 

Measures submitted by small practices will continue to receive 3 points for all future MIPS performance periods.

While the data completeness requirement will remain at 60 percent for the 2019 performance period, we have previously noted our interest in incorporating higher data completeness thresholds in future years to ensure a more accurate assessment of a MIPS eligible clinician’s performance on quality measures and to avoid measure selection bias as much as possible, but believe it should be done so in a gradual manner.

CMS goes on to say:

As discussed in the CY 2018 Quality Payment Program final rule (82 FR 53632), we noted concerns about the unintended consequences of accelerating the data completeness threshold so dramatically, which may jeopardize a MIPS eligible clinician’s ability to participate and perform well in MIPS, particularly with those clinicians who are not as experienced with MIPS quality measure submission. While we do continue to monitor the data completeness threshold with future intentions of raising the threshold for data completeness, we want to ensure that the data completeness requirement is achievable by all MIPS eligible clinicians. We do agree that it is important to incorporate higher data completeness thresholds in future years to ensure a more accurate assessment of a MIPS eligible clinician’s performance on quality measures and to avoid measure selection bias as much as possible, but believe it should be done so in a gradual manner.

In the past, the minimum necessary work to avoid the penalty was considered the “bare minimum”. In 2019, the performance threshold is set at 30 points – doubled from 15 in 2018.  In order to most easily achieve at least 30 overall MIPS points, a small practice should:

1. Submit 1 eligible case per 6 quality measures = 18 points
2. Attest to 1 high-weighted or 2 medium-weighted improvement activities = 15 points
3. Submit Promoting Interoperability hardship exception

This will not be known for certain until CMS releases the MIPS Year 4 final rule in late fall of 2019.

For MIPS performance year 2020, CMS proposed an increase to the performance threshold (the minimum number of MIPS points need to avoid a penalty) from 30 points in 2019 to 45 points in 2020. Because the cost category is supposed to increase in weight from 15% to 20% in 2020, there is somewhat of a risk that can be taken in order to do the bare minimum. Just like in 2019, you will need to attest to 1-4 improvement activities (1-2 for small practices, and 2-4 for all else) and submit 1 case for each of 6 quality measures; this combination of work will give you 27 points out of 100 possible. This is where the risk comes in to play: if you believe you can earn at least an 18 out of 20 in the cost category, then your work is done. You will earn the 45 points necessary to avoid the penalty. {Note: small practices get a little more leeway due to the 6-point small practice bonus which is added to their quality score. No other bonus points are weighed in on this example.}

For those not willing to take the risk (and we wouldn’t recommend it) you will have to participate in all 4 categories to ensure you clear the 45-point mark. This could be a number of combinations but, in our opinion, the most simple would be to 1) submit 1 case for each of 6 quality measures, 2) attest to the number of improvement activities needed to earn full credit, and 3) submit some Promoting Interoperability data (don’t forget your required security risk assessment!) Your cost category will be scored by CMS just like performance year 2018 and 2019 so there is no extra reporting burden on you.

If you work for multiple entities with their own TIN, you must submit MIPS data from each practice that you are required to participant under. You can do this via individual or group submission at each TIN. 

MIPS stands for Merit-based Incentive Payment System