Quality Payment Program Year 3 Reporting Changes: What You Need to Know

The Centers for Medicare & Medicaid Services (CMS) released the final rule for the Quality Payment Program (QPP) year 3 (CY 2019) on Nov. 1, 2018. Below, we have compiled a list of key changes to ensure MIPS-eligible clinicians are accurately reporting for CY 2019:

• New MIPS-eligible clinician types: Physical therapist, occupational therapist, qualified speech-language pathologist, qualified audiologist, clinical psychologist, registered dietician or nutrition professionals;
• Low-volume threshold: MIPS-eligible clinicians will have $90,000 or more in Part B allowed charges, see 200 or more Part B beneficiaries and, new for 2019 eligibility, have performed at least 200 covered professional services from Oct. 1, 2017 to Sept. 30, 2018;
• Ability to opt in: Clinicians or groups who meet or exceed at least one, but not all, of the low-volume thresholds may choose to participate in MIPS to seek the positive payment adjustment;
• Category weight adjusted: The Quality category will be 45% of the overall MIPS score (50% in 2018), and the Cost category will be 15% of the overall MIPS score (10% in 2018);
• Under the Quality category, two rheumatology measures will have substantive changes for the 2019 reporting year:
  1. QPP 176: Rheumatoid Arthritis (RA) Tuberculosis Screening—The timeframe for conducting a TB test prior to an eligible patient’s first course of therapy using a biologic has been extended from six months to 12 months;
  2. QPP 177: RA Periodic Assessment of Disease Activity—To meet the measure, providers will be required to assess each eligible patient’s disease activity level at greater than or equal to 50% of the patients’ visits during the measurement year, as opposed to just once a year. Current RISE registry users will recognize the new measure requirements as those used for ACR 01: Disease Activity Measurement for Patients with RA.
• Small practice bonus: The small practice bonus will be added to the Quality category, rather than the overall MIPS score. The bonus is increased to six points for eligible clinicians in a small practice (15 or fewer eligible clinicians);
• Improvement activities inventory updated: The CMS has added six new qualifying activities, modified five existing activities and removed one activity. We recommend you double-check your planned improvement activities for any changes;
• Promoting interoperability certification requirements: MIPS-eligible clinicians must use 2015 edition certified electronic health record technology (CEHRT). Consult with your EHR vendor regarding their ability to meet this criterion (many EHRs are already using the 2015 edition); and
• Performance threshold: The performance threshold, for neutral payment adjustment, will be 30 points (15 points in 2018). Scores below 30 points will receive a negative payment adjustment; scores above 30 points will receive a positive payment adjustment. The exceptional performance threshold for additional positive payment adjustment is 75 points (70 points in 2018).

ACR Webinar & Other Resources
The ACR remains committed to assisting RISE registry users to understand MIPS requirements and report accurately annually. We will host a webinar at 2:30 p.m. ET on Jan. 9, 2019, to review these changes and answer any initial questions about QPP Year 3. Current RISE users and those interested in joining the registry are encouraged to attend. Additional resources include the CMS MIPS Quick Start Guide and the QPP Year 3 Final Rule Overview Fact Sheet.