Last year, 2018, was the first year where the obligation to use a 2015 Edition Certified EHR technology (CEHRT) was introduced under MIPS. Certain categories, such as Promoting Interoperability, only required this obligation for part of the year.
Calendar year 2019, on the other hand, will require healthcare professionals to attest to all categories using a 2015 Edition CEHRT for the entire year.
Eligible clinicians in MIPS Year 1 (2017) and 2 (2018) included:
For Year 3 (2019) of MIPS, however, the list of eligible clinicians has expanded to include:
Year 1 of MIPS required eligible clinicians to earn at least 3 points out of a possible 100, with Year 2 requiring 15 points. This year, however, the threshold has significantly jumped, requiring clinicians to score at least 30 MIPS points to receive a neutral payment adjustment.
Clinicians aiming to score bonus performance scores needed to earn 70 MIPS points in 2018. For Year 3, they now need to score at least 75 MIPS points.
Although CMS has raised the performance threshold for 2019, they also announced that there would be higher payment adjustments for 2021. Specifically, 2019, based on 2017 performance, will have a maximum possible (+/-) payment adjustment of 4%, with 2020, based on 2018 performance, having a maximum of 5%. As for the year 2021, based on this year’s performance, the maximum possible (+/-) payment adjustment will be 7%.
Many significant changes will be made to the Promoting Interoperability category for Year 3 of MIPS. Having changed names in Year 2 from Advancing Care Information to Promoting Interoperability, this category is also going through the following reconfigurations in Year 3:
Another required measure, although not weighted, will be Security Risk Analysis.
For Year 3, 2018 performance year, only two of four MIPS categories have changed weights. Quality has gone from a scoring weight of 50% to 45%, with Cost changing from 10% to 15%.
As for the year 2019, CMS has added eight new Quality measures and removed 26 measures. These were measures CMS qualified as duplicative or topped out.
It is possible for eligible clinicians to prepare for the changes to come and increase their potential for a higher payment adjustment, or at least a neutral one. Here are a couple of ways to do so:
Although using a 2015 CEHRT in Year 2 gave eligible clinicians an automatic 10 bonus points, it is officially required for year 3, offering no bonus points. With the goal of focusing on performance-based scoring, Year 3 puts emphasis on individual measure scores.
Using a 2014 CEHRT will no longer be permitted in Year 3, leading to no scoring in categories such as Promoting Interoperability if used.
Some eligible clinicians and groups qualify for low-volume threshold and can be exempt from participating in MIPS Year 3 altogether if they meet one of three criteria:
Patient portals have helped not only clinicians connect with their patients, but improved patient satisfaction and helped clinical staff free up valuable time with less incoming calls.
Promoting Interoperability measures can easily be met through the use of patient portals. The integrated communication tools meet measures such as:
All in all, Year 3 of MIPS has expanded the scope of eligible clinicians, reweighed certain categories, and increased performance threshold points and penalties. Through value-based care, CMS aims to streamline the 2019 MIPS program to reduce overall costs and improve patient outcomes.
