The New Year is about to ring in a giant load of compliance and coding changes—from ICD-10, CPT, and HCPCS code set updates to the OIG Work Plan. But while you’re digesting all these 2019 medical coding changes, don’t overlook the Merit-based Incentive Payment System (MIPS) Year 3 changes.
It’s crucial that you understand the major changes to MIPS Quality Payment Program (QPP) for 2019—because they will affect your practice’s compliance efforts and reimbursement, explains coding and billing expert Stephanie Thomas in her webinar, “Prepare for 2019’s Biggest Coding & Documentation Rule Changes.”
CMS Raises the Bar for MIPS Performance
On November 1, the Centers for Medicare & Medicaid Services (CMS) released the 2019 updates to the QPP, which includes the Year 3 MIPS changes. Here’s the scoop:
- Reduced Administrative Burden: CMS will institute policies that move clinicians to a smaller set of objectives and measures and will allow you to use a combination of collection types for the Quality Performance category, according to EHR Intelligence. Certain facility-based clinicians may be able to use facility-based scoring that wouldn’t require data submission. Also, eligible clinicians will be able to retain bonus points in the scoring methodology for complex-patient care and end-to-end electronic reporting.
- Expanded Eligibility: CMS is expanding the definition of “MIPS eligible clinicians” to include physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dietitians or nutrition professionals, MDinteractive
- Increased Thresholds: CMS will double the MIPS performance threshold for clinicians and groups in 2019, from 15 to 30 points. Top-performing clinicians and groups seeking an exceptional performance bonus will need to earn at least 75 MIPS points—a five-point increase from 2018.
- Higher Payment Adjustments: For the 2021 payment year, you will see payment adjustments ranging from -7% to a maximum positive adjustment of +7%.
Small Practices Will Get Bigger Advantages
- More Flexibility for Small Practices: CMS will continue the small practice bonus—but will offer the bonus in the Quality Performance category instead of as a standalone bonus, according to MDinteractive. Also, small practices will get an increased bonus to six points if you submit data on at least one quality measure. And small practices will continue to receive at least three points for measures that don’t meet the data completeness requirements.
- New Determination Period: There will be a single MIPS determination period for the low-volume threshold to identify eligible clinicians as non-patient facing, a small practice, hospital-based, and Ambulatory Surgical Center (ASC)-based. The determination period will be split into two segments: (1) October 1, 2017 to September 30, 2018 and (2) October 1, 2018 to September 30, 2019.
- Adjusted Category Weights: The Quality category weight will drop from 50 percent to 45 percent of your final MIPS score, and the Cost category will increase to 15 percent.
- Overhauled Promoting Interoperability (PI) Category: CMS renamed the Advancing Care Information category; it’s now the Promoting Interoperability (PI) performance category. CMS designed this category to support improved electronic health record (EHR) interoperability and ease providers’ burdens by aligning more closely with the PI Program that applies to hospitals.
Submit Measures Via Multiple Submission Types
- New Opt-In Policy: If a clinician or group meets or exceeds one or two (but not all) of the low-volume threshold criteria, they will be able to “opt in” to MIPS, MDinteractive If you opt into the MIPS program, you’ll be subject to neutral, negative, or positive payment adjustments based on your MIPS performance and final score.
- New Submission Mechanism: CMS will allow you to submit quality measures via multiple submission types. If you submit the same measure via multiple collection types, CMS will use the one with the greatest number of points for scoring.
Key takeaway: You have a lot of 2019 medical coding changes to stay on top of. Make sure you understand how the upcoming MIPS changes will impact your practice and reimbursement in the New Year, stresses Stephanie Thomas in her coding & rule updates webinar.
