Our Healthcare Innovation Solutions (HCIS) professionals have tracked changes to the 2020 Merit-based Incentive Payment System (MIPS) final rules that practices need to be aware of. Below is an overview of 2020 eligibility rules, timelines, and performance categories.
The 2020 (a.k.a. Year 4) performance period runs from January 1 to December 31, 2020. The deadline for submitting data is March 31, 2021, though clinicians are encouraged to submit earlier. The Centers for Medicare and Medicaid Services’ (CMS) will apply payment adjustments to each claim beginning on January 1, 2022.
MIPS measures performance in four weighted categories – Quality (45%), Improvement Activities (15%), Promoting Interoperability (25%), and Cost (15%). A practice’s MIPS Final Score is calculated by adding together the points from each category, and this determine if a practice receives a positive, negative, or neutral payment adjustment from CMS. The stakes are substantial — the maximum adjustment ranges between 9% and -9% in 2020, up from 7% and -7% in 2019.
|Final Score 2020||Payment Adjustment in 2020|
|≥85 Points||Positive Adjustment + Exceptional Performance Bonus|
|45.01 – 84.99 Points||Positive Adjustment|
|45 Points||Neutral Adjustment|
|11.26 to 44.99 Points||Negative Adjustment between -9% to 0%|
|0 to 11.25 Points||Negative Adjustment of -9%|
2020 MIPS Changes
Category weights have not changed from 2019, but CMS has modified how they’re measured. For instance, CMS is removing 39 measures from the most heavily weighted category, Quality. This includes low-bar, standard of care, and process measures. Meanwhile, CMS is adding new specialty sets for speech/language pathology, audiology, clinical social work, chiropractic medicine, pulmonology, nutrition and endocrinology in 2020.
CMS also modified the benchmarks for some performance categories for 2020 to avoid the potential for inappropriate treatment. For this reason, controlling high blood pressure now has a flat percentage benchmark.
Within the Cost category, CMS is changing total per-capita cost (TPCC) attribution to exclude some clinicians who primarily deliver certain non-primary care services.
Promoting Interoperability is also seeing changes for 2020. For instance, groups will be identified as hospital-based and eligible for re-weighting when more than 75% of members meet the definition of a hospital-based individual MIPS-eligible clinician. This is down from 100% in 2019. In addition, clinicians and practices will no longer be able to report the Verify Opioid Treatment Agreement bonus measure.
“The new rules are designed to reduce the reporting burden by limiting the number of required specialty or condition-specific measures,” says NJII-HCIS MIPS Adviser Patrick Cordes.
Further information about MIPS and the Quality Payment Program (QPP) can be found at CMS’s QPP resource library.
What Clinicians are Eligible in 2020?
Eligibility to participate in MIPS in 2020 is the same as in the 2019 reporting year.
MIPS participation is mandatory for many clinicians that meet three low-volume thresholds. These minimums are (1) having more than 200 Medicare Part B patients, (2) having more than $90,000 in associated medical billing per year, and (3) covering more than 200 professional services during the performance period. They also need to be one of the following types of clinicians.
- Physician Assistants
- Nurse Practitioners
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
- Clinical Psychologists
- Physical Therapists
- Occupational Therapists
- Speech/Language Pathologists
- Nutrition Professionals
Of course, if a clinician does not exceed all three of the low-volume threshold criteria they may wish to voluntarily participate in MIPS in order to receive feedback on their performance. Additionally, if a clinician exceeds at least one of the three criteria they may elect to opt-in and be eligible for a positive adjustment. Clinicians can check their participation status with CMS by using their National Provider Identification Number here.
Cordes and fellow MIPS Adviser Madelin Hernandez recently led a webinar on 2020 rule changes. You can view the discussion here.
NJII’s Healthcare Division has served as a CMS-qualified data registry since 2011 and helped more than 10,000 large and small practices, health systems, and a range of billing and Electronic Medical Record (EMR)/Electronic Health Record (EHR) vendors. For the 2018 reporting year alone, our MIPS team helped more than 4,300 providers and 620 practices submit care data to CMS, ensuring they received an estimated $6 million in incentive payments and avoided $25.9 million in penalties.
CMS created MIPS in 2017 by blending and modernizing elements of earlier initiatives, including the Medicare EHR Incentive Program for Eligible Clinicians, the Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier. MIPS uses its payment incentives to push practices to adapt value-based care.
HCIS, the for-profit arm of the New Jersey Innovation Institute’s (NJII) Healthcare Division, hosts webinars periodically on MIPS requirements, developments and rule changes. Last year, the MIPS team hosted a webinar detailing last-minute reporting tips for 2019. Learn more about our MIPS services and sign up for 2019 reporting on our site.