A Summary of the 2020 MIPS Proposed Rule

Today, CMS posted CY 2020 Updates to the Quality Payment Program to the Federal Register. Many clinicians are still trying to wrap their heads around how to report MIPS in 2019, but the release of the 2020 proposed rule is advantageous in deciding what to conquer both this year and in the future. As the title suggests, this document also covers other Quality Payment Program tracks, like Advanced APMs; however, for now we will just focus on the MIPS component of the proposed rule.

Most Important Proposed Changes for 2020

• The performance threshold (the minimum score for penalty avoidance), set at 30 points in 2019, will be 45 points in 2020 and 60 points in 2021. CMS is also proposing to increase the additional performance threshold for exceptional performance to 80 points in 2020 and to 85 points in 2021.
• The Quality category weight will be reduced to 40% in 2020, 35% in 2021, and 30% in 2022, while Cost will be increased to 20% in 2020, 25% in 2021, and 30% in 2022.

Proposed Changes By Category

Quality - 40% in 2020

The data completeness threshold will be raised from 60% to 70%. CMS proposes continuing to remove low-bar, standard of care, process measures, focus on high-priority outcome measures, and add new specialty sets, including Speech Language Pathology, Audiology, Clinical Social Work, Chiropractic Medicine, Pulmonology, Nutrition/Dietician, and Endocrinology.

In addition to current requirements, measures submitted in response to Call for Measures would be required to demonstrate a link to existing and related cost measures and improvement activities as appropriate and feasible.

In addition to current measure removal criteria:

• MIPS quality measures that do not meet case minimum and reporting volumes required for benchmarking for 2 consecutive years would be removed.
• CMS may consider a MIPS quality measure for removal if they determine it is not available for MIPS Quality reporting by or on behalf of all MIPS eligible clinicians (including via third party intermediaries).

Beginning in the 2022 MIPS payment year, CMS plans to establish flat percentage benchmarks in limited cases where CMS determines that the measure’s otherwise applicable benchmark could potentially incentivize treatment that could be inappropriate for particular patients.

Cost - 20% in 2020

CMS proposes revising the current measures and adding 10 new episode-based measures:

1. Acute Kidney Injury Requiring New Inpatient Dialysis
2. Elective Primary Hip Arthroplasty
3. Femoral or Inguinal Hernia Repair
4. Hemodialysis Access Creation
5. Inpatient Chronic Obstructive Pulmonary Disease (COPD) Exacerbation
6. Lower Gastrointestinal Hemorrhage
7. Lumbar Spine Fusion for Degenerative Disease, 1-3 Levels
8. Lumpectomy Partial Mastectomy, Simple Mastectomy
9. Non-Emergent Coronary Artery Bypass Graft (CABG)
10. Renal or Ureteral Stone Surgical Treatment

Promoting Interoperability - 25% in 2020

In 2020, CMS proposes that a group would be identified as hospital-based and eligible for reweighting if more than 75% of the NPIs in the group meet the definition of a hospital-based individual MIPS eligible clinician. For non-patient facing groups (more than 75% of the MIPS-eligible clinicians in the group are classified as non-patient facing) CMS would automatically reweight the Promoting Interoperability performance category.

Beginning with the 2019 performance period, CMS proposes to require a yes/no response for the Query of PDMP measure. CMS would redistribute the points for the Support Electronic Referral Loops by Sending Health Information measure to the Provide Patients Access to Their Health Information measure if an exclusion is claimed. Beginning with the 2020 performance period, CMS proposes to remove the Verify Opioid Treatment Agreement Measure and to keep the Query of PDMP measure as optional.

Improvement Activities - 15% in 2020

CMS proposes the following related to this performance category:

• To modify the definition of a rural area;
• To remove the criteria for patient-centered medical home designation that a practice must have received accreditation from one of four accreditation organizations that are nationally recognized or comparable specialty practice that has received the NCQA Patient-Centered Specialty Recognition;
• To increase the participation threshold for group reporting from a single clinician to 50% of the clinicians in the practice;
• To update the Improvement Activity Inventory and establishing criteria for removal in the future; and
• To conclude the CMS Study on Factors Associated with Reporting Quality Measures.