2019 CMS Quality Payment Program (QPP) Changes
In 2019 the Centers for Medicare and Medicaid (CMS) are making changes to the Quality Payment Program (QPP). Below are the most impactful changes we think you need to know about. For additional information, click one of the links at the bottom of this post.
Performance thresholds increase substantially
- Performance threshold to receive a positive adjustment has increased from:
- 3 points in 2017, to 15 points in 2018, and now 30 points in 2019.
- CMS anticipates continuing to increase this threshold by 15 points yearly.
- Exceptional Performance Threshold increases to 75 Composite Points.
Projected Median of Composite MIPS Scores to drop by 12% according to CMS
MIPS Eligibility Expanded
- CMS estimates 180,000 more eligible clinicians.
- Physical Therapists, Occupational Therapists, speech pathologists, audiologists, midwifes, clinical psychologists, nutritionists, and dieticians all newly eligible.
- Note that Clinical Social Workers were included on the 2019 Proposed Rule, but ultimately excluded.
- Opt In options for low-volume clinicians. Low-volume clinicians are defined as meeting one of the following conditions:
- >200 Part B patients per year
- >$90k Part B billed charges
- >200 services (newly introduced in 2019)
MIPS financial impact continues to become more relevant
- Projected maximum incentive to increase from:
- 88% increase in 2017 to an estimated 1.9% in 2018 to 4.7% in 2019.
- Projected maximum incentive increases
- Penalty Impact for low performance increases from +/- 5% in 2018 to +/-7% in 2019, CMS projects the total penalty/bonus money to hit roughly $390 million.
- Projected maximum incentive increases as more clinicians receive substantial penalties. This bonus money available will become continuously more noticeable.
Hospital-based clinician flexibility
- Facility-based reporting will be utilized for MIPS Quality and Cost categories by scoring on relative performance in the hospital value-based payment programs (VBP). Percentile-based performance from VBP will be proxied as a MIPS Quality performance for those providers.
- Eligibility is targeted to be viewable on the QPP portal Q1 2019, CMS will also automatically determine whether quality reporting OR VBP reporting will give these providers a higher score.
Other Payer Advanced APMs offered more options
- Yearly certification adjusted to a 3-year application process between payers and CMS for commercial value-based contracts to account for Advanced APM participation on behalf of included clinicians
- Oncology, and cardiology programs likely to develop in mandatory models that were previously rolled back
MIPS Cost weight increases from 10% in 2018 to 15% in 2019
- Medicare Spending Per Beneficiary (MSPB) and Total Per Capita Cost (TPCC) continue without change
- 8 new episode-based measures introduced with a 10 case threshold for procedural episodes and 20 for inpatient episodes
- Set to increase to 30% by law
MIPS Promoting Interoperability scoring becomes more difficult
- In 2019, the max PI score is 100, with 10 additional bonus point opportunities as opposed to the 155 possible points in 2018
- The base/performance subcomponents within the PI category will be removed
- Fewer overall measures will be available for reporting with four objectives:
- e-Prescribing
- Health Information Exchange
- Clinical Data Exchange
- Provider to Patient Exchange
- 2015 CEHRT requirement stands (2015 CEHRT earned a bonus in 2018, it was not a requirement)
- Sending and Receiving Transitions of Care measures consolidated with previous medical reconciliation measures
MIPS Quality Adjustments
- Alignment with CMS’ Meaningful Measures Initiatives to focus on measures that:
- Address high-impact public health areas
- Patient-centered and understandable to patients
- Outcome-based (Patient Reported)
- Minimize administrative burden (through a preference for EHR-based measures)
- Priority to continue Patients over Paperwork Initiative
- Claims submission only available for small practices
- Individuals and groups will be able to use multiple collection types
- Opioid-related measures now added to high priority measures
- CMS Web Interface reduced from 14 to 9 measures for MIPS Quality and Medicare ACOs
- High priority-measure bonus removed from those using the web interface because they don’t choose their own measures anyways
- Generally, fewer paths available to earn full credit with quality measures
- Thresholds continue to become more difficult to meet
For further information, CMS recently released the following resources:
SHP’s Performance Analytics services can help you better understand your data so you can ensure you’re meeting key performance indicators. Click here to learn more.