For the fourth year of MIPS performance in 2020, which impacts 2022 payment, CMS finalized modifications to the QPP, which includes MIPS and Advanced Alternative Payment Models (APMs).
2020 MIPS Threshold: Despite opposition from ASCRS and the medical community, CMS is increasing the MIPS performance threshold to 45 points, up from 30 in 2019. MIPS participants must score at or above the performance threshold to avoid a penalty.
Exceptional Performance Threshold: CMS is increasing the exceptional performance threshold that awards participants for higher MIPS scores with additional bonuses to 85 points in 2020. CMS had proposed only to increase it to 80 points up from 75 points in 2019 but following analysis of 2018 MIPS performance data increased it beyond the proposed level in the final rule.
Scoring Considerations: CMS is maintaining all of its previously finalized scoring modifications, such as for small practices: the Promoting Interoperability hardship, small practice bonus in Quality, and reduced requirements in Improvement Activities. In addition, it will continue to offer bonus points for complex patients and add bonus points to the Quality score for electronic submission and additional outcome or high priority measures.
Payment Adjustments: In line with the MACRA statute, the total possible penalty or bonus in 2022, based on 2020 performance, increases to 9%. This is the final increase included in MACRA. Total possible payment adjustments will remain at this level for the duration of the MIPS program. It is important to remember, however, that due to the budget-neutral nature of the MIPS program, participants will likely not receive bonuses as high as 9%.
MIPS Category Weights: Instead of increasing the weight of the Cost category and decreasing the weight of the Quality category as it had proposed, CMS is maintaining the same category weights in 2020 as in 2019. These weights are:
- Quality – 45%
- Cost – 15%
- Promoting Interoperability – 25%
- Improvement Activities – 15%
MIPS Performance Categories:
Quality: CMS increased the data completeness threshold for quality measures to 70% of all patients for registry and EHR submissions and 70% of Part B patients for claims reporting, up from the current 60% level. In addition, as part of the ASCRS-opposed topped-out measure methodology, CMS removed two measures: Measure 192, Cataracts: Complications within 30 Days Following Cataract Surgery Requiring Additional Surgical Procedures, and Measure 388, Cataract Surgery with Intra-Operative Complications (Unplanned Rupture of Posterior Capsule Requiring Unplanned Vitrectomy). Following opposition from ASCRS and the medical community, CMS is not finalizing an additional claims-based population health measure for chronic conditions for 2021.
Cost: As a major win for ASCRS and other specialists, CMS finalized a modified attribution methodology to exclude ophthalmologists and optometrists, as well as other non-primary care providers, from the total per capita cost measure. We have long opposed the attribution methodology in this measure that potentially holds physicians responsible for the cost of care they did not provide. CMS did not respond to ASCRS comments opposing the inclusion of pass-through drugs in the cataract episode-based cost measure. We will continue to advocate for this change.
Improvement Activities: CMS finalized a modified version of its proposal for group reporting of this category. Currently, if only one clinician in the group is participating in an improvement activity, then the entire group may report it for credit. CMS proposed that at least 50% of the group’s clinicians participate in the improvement activity. In the final rule, CMS said it was finalizing the change to require 50% of participants in the group complete the activity, however, participants will not all have to complete the activity within the same 90-day period during the year.
Promoting Interoperability: Since CMS made major changes to the category in 2019, it only made minor modifications for 2020. Specifically, CMS removed one of the voluntary opioid-related measure and modified the remaining one. However, ophthalmologists will continue to be likely unable to report the remaining opioid measure, which is still voluntary.
MIPS Value Pathways (MVPs)
In the proposed rule, CMS included a request for information about a new participation pathway in MIPS, the MVPs, that would include a required set of measures and activities centered on a particular condition or procedure beginning in 2021. MVPs would also include problematic population-based measures geared toward primary care. ASCRS and the medical community opposed the mandatory nature of the MVPs in our comments on the proposed rule and urged CMS to make them voluntary and continue to provide options for physicians to select the measures and activities that best reflect their practices. In the final rule, CMS notes that it has not yet made formal proposals related to the MVPs and has not yet determined whether it will propose that the MVPs will be mandatory. CMS stated that it will work with stakeholders, including medical societies, to develop MVPs.
ASCRS is continuing to analyze the final rule and will be updating our MACRA Center and in-depth guides shortly. ASCRS and ASOA are also offering a webinar on the final rule at 2:00 p.m., ET on Friday, November 22. Click here to register.
We will also be submitting comments on the final rule.
If you need additional assistance, please contact Allison Madson, manager of regulatory affairs, at firstname.lastname@example.org or 703-591-2220.