The Centers for Medicare & Medicaid Services (CMS) released the 2020 Proposed Rule for the Quality Payment Program (QPP) on July 29. We have compiled a list of key changes to assist our MIPS-eligible clinicians with accurate reporting for calendar year 2020.
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- The performance threshold for neutral payment adjustment would be raised to 45 points, from 30 points in 2019. Scores below 45 points would receive a negative payment adjustment; scores above 45 points would receive a positive payment adjustment.
- The exceptional performance threshold for an additional positive payment adjustment would be raised to 80 points, from 75 points in 2019.
Providers stand to gain or lose up to 9% for performance year 2020 (to be paid in calendar year 2022).
Performance category weights
Following precedent, the CMS is recommending reducing the impact of the Quality category and increasing the impact of the Cost category:
- Quality = 40% of total score (vs. 45% in 2019)
- Cost = 20% of total score (vs. 15% in 2019)
Data completeness requirements
The minimum sample size would increase to 70% of Medicare Part B patients (from 60% in 2019) for reporting the Quality category.
- “Rural area” will be determined by the Federal Office of Rural Health Policy’s ZIP code files.
- The proposal includes the addition of two new activities, modification of seven activities and removal of 15 existing activities (see Appendix 2 in the Proposed Rule for details).
- A group would be able to attest to an improvement activity when at least 50% of MIPS-eligible clinicians participate in the activity (previously only one clinician in the TIN was required to participate).
Cost performance category
- The proposed rule includes a revised version of the TPCC and MSPB-C (formerly MSPB) measures.
- Ten new episode-based measures would be added to the program.
All requests for targeted review would be due within 60 days of the release of performance feedback.
In the 2020 proposed rule, the CMS also gives insights into the years ahead. In 2021, the performance category weights would further adjust the Quality score to 35% and Cost to 25% of the total score. In 2022, the Quality and Cost categories would have equal weight—30% each—per the requirement set forth by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
Additionally, the performance threshold adjustments expected in 2021 are 60 points for a neutral payment adjustment and 85 points for the exceptional performance threshold.