MIPS Participation: Wrapping up 2018 and Getting Started in 2019

Eligible providers now have two performance years of the Centers for Medicare and Medicaid Services’ (CMS) Merit-Based Incentive Payment System (MIPS) under their belts. As we begin year three, here are a few reminders for wrapping up 2018 reporting and preparing for ongoing participation in 2019.

Wrapping up 2018

As you finish your MIPS participation for 2018, keep the following in mind:

Eligible providers have until April 2, 2019, to submit 2018 MIPS data (except for CMS Web Interface users who must report quality data from January 22, 2019, to March 22, 2019).
For clinicians who reported Quality measures via Medicare Part B claims, quality data will be extracted from claims processed by your Medicare Administrative Contractor (MAC). Please note that claims for 2018 dates of service must be processed within 60 days after the end of the 2018 performance period in order to be included in the MIPS program.
To submit your MIPS data, follow the steps outlined below:
1. Go to the Quality Payment Program website
2. Log-in using your QPP access credentials (download instructions)
3. Submit your MIPS data for Year 2 (2018)

Getting Started in 2019

For 2019, payment adjustments based on 2017 participation will affect all Medicare Part B Physician Fee Schedule payments. The good news is that most participating providers will receive at least a small positive payment adjustment, according to CMS. However, if you were among the 9 percent of eligible providers who didn’t participate in MIPS in 2017, or among the 5 percent who did but didn’t meet the program requirements for “successful” participation, expect a 4 percent negative payment adjustment on 2019 payments.

In addition to newly applied payment adjustments, here are a few other things you need to know about MIPS for 2019:

New eligibility guidelines mean several new provider types are now responsible for participating in MIPS, including physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dietitians or nutrition professionals. Providers can check their eligibility status both as individuals and groups using CMS’s MIPS Participation Status calculator. (NOTE: As of January 15, 2019, the MIPS calculator had not been updated to reflect 2019 eligibility specifications.)
CMS also added a third criterion for determining MIPS eligibility under the Low-Volume Threshold. For 2018, clinicians or groups were excluded from MIPS if they had ≤ $90K in Part B allowed charges for covered professional services or if they provided care to ≤ 200 beneficiaries. In addition to those two criteria, for 2019, clinicians or groups may be excluded if they provide ≤ 200 covered professional services under the Physician Fee Schedule (PFS).
However, CMS also has created a new “opt-in feature” for excluded clinicians and groups. For 2019, clinicians or groups would be able to opt-in to MIPS if they meet or exceed one or two, but not all, of the low volume threshold criterion.
The MIPS Participation Status calculator also will alert providers to any special status that may affect their participation, like being part of a small practice, or qualifying as hospital-based and non-patient-facing providers. These special statuses can affect your program requirements, especially as it relates to the Promoting Interoperability performance category. You can learn more about those provisions in the MIPS section of our blog post “2019 Medicare Physician Fee Schedule: What You Need to Know.”
Payment adjustments for 2019/2021 will be +/- 7 percent up from +/- 5 percent in 2018/2020. The various performance categories will be weighted as follows for 2019/2021: Cost — 15 percent; Quality — 45 percent; Improvement Activities — 15 percent; and Promoting Interoperability — 25 percent.
For the 2019 performance year, MIPS participants must earn 30 points to avoid a 7 percent negative payment adjustment. In 2018, MIPS participants avoided a 5 percent negative payment adjustment by earning just 15 points.
In addition to receiving a new name, the Promoting Interoperability Performance Category (formerly Advancing Care Information) will require eligible clinicians to use 2015 Edition CEHRT in 2019.
For providers planning to submit data via an outside registry, lists of approved qualified registries and qualified clinical data registries have been published by CMS for 2018. You can find those on the QPP Resource Library by filtering on 2019 Performance Year, MIPS QPP Performance Track, and Technical Guides and User Guides Resource Type.
Finally, in 2019, MIPS eligible clinicians and groups who furnish 75 percent or more of their covered professional services in sites of service identified by inpatient hospital or emergency room POS codes will be evaluated under the Hospital Value-Based Purchasing (VBP) Program rather than MIPS scoring. CMS will automatically apply facility-based measurement to facility-based MIPS eligible clinicians and groups who would benefit by having a higher combined quality and cost score. There are no submission requirements for individual clinicians who receive facility-based measurement, but groups must submit data in the Improvement Activities or Promoting Interoperability performance categories in order to be measured as a group under facility-based measurement.

For more information about MIPS in 2019, review the following: