The Centers for Medicare & Medicaid Services (CMS) has submitted its annual proposed rule for comment from stakeholders and the public for the 2019 MIPS performance year (PY). This period covers Jan. 1, 2019–Dec. 31, 2019. The proposed rule continues the transition process away from a fee-for-service model to a value-based model until full implementation in 2020.
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Increasing Performance Thresholds
Since the first transition year in MIPS, the CMS continues to increase both the performance and additional performance thresholds annually.
The performance threshold is the points a provider/practice must score to avoid a negative payment adjustment and qualify for a neutral payment adjustment. CMS established a 15-point performance threshold in the 2018 PY and is proposing a 30-point threshold for 2019. The most significant impact of the increase in the performance threshold will be on providers who still have not transitioned to an electronic health record (EHR). It will become increasingly difficult to achieve a neutral payment adjustment for these providers because the program continues to increase in difficulty. The higher the score above the performance threshold, the greater the positive payment adjustment.
In 2018, the additional payment adjustment for exceptional performance is for scores that are 70 points or higher. The amount of the adjustment is also applied on a linear scale so clinicians with higher scores receive a higher adjustment. The 2019 proposed rule increases this threshold to 80 points. Under this policy, higher performing providers would most likely receive more substantial payments because fewer providers are receiving these additional payments.
3 MIPS Proposals That Impact Private Practice
Three particular policies will affect private and, more particularly, small practices the most.
1. Recalculating small practice bonus:In 2018, CMS added a five-point small practice bonus to the final score of all practices with 15 providers or less. With a maximum total score of 100 points, this bonus increased a practice’s score by 5%. The 2019 proposal states the following:
“The small practice bonus will now be added to the Quality performance category, rather than in the MIPS final score calculation. Add 3 points in the numerator of the Quality performance category for MIPS eligible clinicians in small practices who submit data on at least one quality measure.”
This would reduce the positive impact of the bonus from 5% (2018) to 1.35% (2019) to the overall final score. The 2018 application of the small practice bonus was very helpful to these providers who do not have the same resources as other large practices or hospitals who have more to spend on MIPS compliance.