Get the scoop on MIPS changes for 2019

Get the scoop on MIPS changes for 2019

It’s a new year, and that means a new set of policies for the Merit-Based Incentive Payment System (MIPS). Our chart below outlines all the major changes taking place, but here are some of the highlights:

  • The potential penalty for non-participation increases from 5% to 7% in 2019. Penalties or bonuses from 2019 MIPS performance will influence payment in 2021.
  • Allergists will have to do more to avoid a penalty; you now need 30 MIPS points (up from 15 in 2018) to avoid a penalty.
  • Allergists looking to get an exceptional performance bonus will also have to do more – the bonus threshold increases to 75 points from 70 in 2018.
  • 2015 edition certified electronic health record technology (CEHRT) is required in 2019. However, there is a new hardship exception for providers whose vendors will not be providing a 2015 CEHRT version.
  • Small practices (those with less than 16 providers) still qualify for a Promoting Interoperability (PI) hardship exception. They also still qualify for a five-point small practice bonus, but the bonus is applied to their quality score, not their full MIPS score. Finally, small practices can now report quality measures via claims as a group; previously, claims reporting was only allowed for individuals.

The online Quality Payment Program (QPP) doesn’t yet have a lookup to determine whether you’re required to participate in 2019, but your participation status for 2018 will give you a good indication. If you must participate, start planning now. Some suggested first steps to take are to:

  • Determine your 2019 MIPS goal such as avoiding a penalty, maximizing your bonus, etc.
  • Establish a reporting strategy.
  •  Ask your EHR vendor if they have 2015 CEHRT.
  • Assess your past performance to determine how you can improve.

The potential penalty for non-participation is becoming significant, but with careful planning, you can avoid it! Stay tuned to Advocacy Insider for more useful MIPS tips for allergists as the year unfolds.

MIPS polices for 2018 vs. 2019

POLICY20182019
Penalty or bonus+/- 5% (in 2020)+/- 7% (in 2021)
Reporting period*Quality and cost: full calendar year
PI and IA: any 90 days
Quality and cost: full calendar year
PI and IA: any 90 days
Category weights*Quality: 50%
Cost: 10%
PI: 25%
IA: 15%
Quality: 45%
Cost: 15%
PI: 25%
IA: 15%
Low volume threshold$90,000 Medicare charges OR
200 patients
$90,000 Medicare charges OR
200 patients OR
200 covered services
CEHRT edition2014 or 20152015 only;
a hardship exception is available for those without 2015 CEHRT
Small practice bonus
(<= 15 providers)
5 points to total score5 points for Quality
Complex patient bonus5 points to total score5 points to total score
Quality data submission optionsMust submit quality data via one submission methodCan submit quality data via multiple submission methods (EHR, registry, etc.)
Quality reporting via claimsOnly available for individual reportingNow available for group reporting for small practices (<= 15 providers)
Promoting Interoperability (PI) hardship exemptionSmall practices (<= 15 providers) qualifySmall practices (<= 15 providers) qualify
Minimum points to avoid a penalty15 points30 points
Exceptional performance threshold to receive an extra bonus70 points75 points

* PI = Promoting Interoperability, IA = Improvement Activities

The new MIPS access system: HARP

The Centers for Medicare and Medicaid Services (CMS) just rolled out a new account management system for the QPP: the HCQIS Access Roles and Profile (HARP) system. The change is effective immediately, so now you’ll use HARP instead of the Enterprise Identify Management (EIDM) system for things like reporting MIPS data, checking group MIPS eligibility status, accessing Physician Compare, downloading feedback and reviewing final MIPS scores and payment adjustments. (EIDM accounts will still be used for other programs, such as Open Payments; HARP is only for the QPP.) 

If you had an existing EIDM account, CMS should have already created a HARP account for you. If you’re new to QPP, you must create a new HARP account. You can log in or create a new account at the QPP website. For more information, download the QPP access user guide zip file. The Advocacy Council recommends you log into or create your HARP account soon to confirm there are no issues. 

Advocacy Issue: 
MIPS