Get the scoop on 2020 MIPS changes

| February 10, 2020

Get the scoop on 2020 MIPS changes

It’s a new year, and that means a new set of policies for the Merit-Based Incentive Payment System (MIPS). Many of the reporting requirements remain the same as last year, but there are a few key changes. Our chart below outlines all the major changes taking place in 2020, but here are some of the highlights:

  • The potential penalty for nonparticipation increases from 7% in 2019 to 9% in 2020. Penalties or bonuses from 2020 MIPS performance will influence payment in 2022.
  • Allergists will have to do more to avoid a penalty; you now need 45 MIPS points (up from 30 in 2019) to avoid a penalty.
  • Allergists looking to get an exceptional performance bonus will also have to do more – the bonus threshold increases to 85 points (from 75 in 2019).
  • For Improvement Activities, the participation threshold for group reporting has increased from a single clinician to 50% of clinicians in the practice.
  • For Quality, the data completeness threshold has increased from 60% to 70% of patient encounters.

If you haven’t done so already, check your MIPS participation status for 2020. If you must participate, get started now. CMS has improved their MIPS resources over the past few years. They now have several helpful resources in the QPP Resource Library that provide details about the program, which we’ve outlined below.

The potential penalty for nonparticipation is becoming significant, but with careful planning, you can avoid it!


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Policy 2019 2020
Penalty or bonus +/- 7% (in 2021) +/- 9% (in 2022)
Reporting period* Quality and cost: full calendar year

PI and IA: any 90 consecutive days

No change
Category weights* Quality: 45%

Cost**: 15%

PI: 25%

IA: 15%

No change
Low volume threshold $90,000 Medicare charges OR

200 patients OR

200 covered services

No change
CEHRT edition 2015 Only; a hardship exception is available for those without 2015 CEHRT No change
Small practice bonus (<= 15 providers) 6 points for Quality No change
Complex patient bonus Up to 5 points to total score No change
Other Quality category bonuses Improvement bonus (up to 10 points) for improvement to Quality score over prior year

Electronic submission of quality data (up to 6 points)

Additional measures submission (up to 6 points)

No change
Quality data submission options Can submit quality data via multiple submission methods (EHR, registry, etc.) No change
Quality reporting via claims Available for group reporting for small practices (<= 15 providers) No change
Promoting Interoperability (PI) hardship exemption Small practices (<= 15 providers) qualify; must submit a hardship application No change
Quality data completeness threshold 60% of patient encounters 70% of patient encounters
Improvement Activities group reporting participation threshold A single participating clinician counts for the whole group 50% of clinicians in the practice must participate and report the same IA
Minimum points to avoid a penalty 30 points 45 points
Exceptional performance threshold to receive an extra bonus 75 points 85 points

*PI = Promoting Interoperability, IA = Improvement Activities
**10 new episode-based measures were added to the Cost category.

CMS MIPS resources in the QPP Resource Library

The 2020 MIPS Quick Start Guides are a series of guides that explain how clinicians can start participating in MIPS during the 2020 performance period. They include: 

More resources are:

  • 2020 MIPS Data Validation Criteria  Includes the criteria used to audit and validate data submitted in each performance category. The Improvement Activities data validation criteria is available now and the remaining categories will be added to the zip file at a later date.
  • 2020 Quality Benchmarks – Lists and explains 2020 benchmarks used to assess performance in the Quality Performance category.
  • 2020 Qualified Registries Qualified Posting – Lists the vendors approved by CMS to be Qualified Registries for the 2020 MIPS performance period.
  • 2020 QCDRs Qualified Posting – Lists the vendors approved by CMS to be Qualified Clinical Data Registries (QCDRs) for the 2020 MIPS performance period.