Check if your practice qualifies for the small practice bonus in 2018 via the CMS’s NPI look-up tool here.
2. The increasing weight of the Cost category:The 2019 proposed rule continues the importance of cost in the MIPS final score at the expense of the Quality category. The current 2018 performance year has Cost at 10% and the Quality category at 50%. The 2019 proposed rule would reduce Quality to 45% and increase Cost to 15% of a provider’s final MIPS score. This proposal would continue the final score weighting from a category (Quality) that providers have total control over to a category (Cost) that providers have almost no power over. to a category (Cost) that providers have almost no power over. Although high drug costs will be counted in the cost measure, MIPS adjustments will not be applied to the high sums of Part B drug infusions—as a result of pressure by many advocates including the ACR.
3. Mandating 2015 Edition of Certified Electronic Health Record Technology (CERHT): The 2019 proposed rule will no longer allow for the use of 2014 CERHT technology. The current 2018 PY allowed for the use of 2014 CERHT but gave a 10% bonus to practices who utilized 2015 CERHT.
The impact on providers who do not currently use 2014 CERHT would mean they could not accrue any of the 25 points dedicated to this category. Practices would still be able to meet or exceed the proposed 30-point performance threshold, the maximum possible score they could achieve in categories that are in their control would be 60 points (45 from quality + 15 from Improvement Activities). They could achieve anywhere between zero and 15 additional points in the cost category for a maximum score of 75.
Comments Due to CMS in Mid-September
The ACR will comment all on policies in the 2019 MIPS proposed rule. A copy of the comment letter the ACR submits to CMS will be here. All providers are encouraged to submit letters to CMS as well and explain the adverse impact these proposals will have on their practice and patient care.
To ensure you are prepared for MIPS in 2018 and all future years, rheumatology providers should join the ACR’s RISE Registry. Every member who completed a full submission via the RISE Registry in 2017 qualified for financial incentives. Moreover, a significant number of these providers received a perfect score and qualified for the largest bonuses.
