Each year, the Centers for Medicare and Medicaid (CMS) release the Final Rule that outlines the changed polices and program requirements for the Merit-based Incentive Payment System (MIPS). In the 2020 Final Rule, much has been carried over from the previous year, but there are key modifications that we believe to be critical.
Much like with New Year’s resolutions, MIPS 2020 will require immediate attention and consistency to be successful. Just like a failed resolution, lack of action will have you throwing your hands in the air and waiting to begin again in January 2021.
Know before you go
It’s important to be introspective and evaluate where you are before you resolve whether to make any resolutions. As far as MIPS goes, ask yourself…
- What tools and technology will my practice use in 2020?
- Do I know what the 2020 MIPS requirements are? If not, you might listen to or read these updates.
- Am I willing to get started in Q1 2020 to achieve a good score? (Because that’s what it’s going to take.)
- Do I just want to avoid a penalty or would I like to be a top performer? (NOTE: Even avoiding a penalty in 2020 is hard!)
Regardless of your answers, especially on that last bullet, here are some important things to consider:
MIPS is not as easy as it used to be
Just like those extra 10 pounds you try and lose as you get older, MIPS is getting harder and harder to tackle. The Quality data completeness threshold has been raised to 70 percent in 2020. That means when one of the measures you choose applies to an encounter or service code, you have to collect it for 70 percent of the patients you see in the year, regardless of their insurance provider.
To be successful you need to pick out your six measures and start collecting data right away. Getting started early will be critical to your success.
Your success this year requires a strategy
Here’s the real kick in the pants: you’ll need to earn more than 45 overall MIPS points just to avoid a penalty! The penalty can reach as high as nine percent.
*Estimated payment adjustments in 2022 based on 2020 performance.
**Subject to finalization by CMS including consideration for budget neutrality
In order to ensure you achieve more than the minimum required points, plan on participating in as many categories as possible.
Here are some ideas about each of them that can help:
Quality is “king” as we like to say. Pick out six measures and consider the following:
What measures do I have the opportunity to collect?
This means assessing what tools and technology you use and what features and functionality they offer. If they track things you don’t care about or measures that don’t make sense for which to collect data, consider the MIPSPRO registry.
What is the overall point potential for each of your quality measures?
Look at the prior year benchmarks and corresponding deciles. This will tell you based on your overall performance the maximum number of points you can earn.
Can my practice reasonably collect this data all year long?
Cumbersome data collection for measures and infrequent opportunities to capture may leave you with not enough data by the end of the year. Your focus should be on making sure quality data collection is easy to document or chart. Those who capture the data in your practice may feel overwhelmed and/or confused, which will make hitting the 70 percent data completeness requirement that much more difficult.
Improvement Activities (IA) should be a pretty straight forward opportunity to earn 15 points. Be sure to review your IA choices. Many have been edited or removed, especially those tied to Quality Clinical Data Registries (QCDRs). Make sure you know exactly what is required for each and be sure you actually do them for 90 days.
If reporting as a group, one major change for 2020 is that 50 percent of the clinicians in your groups must perform the activity. In the past, CMS gave full credit for just one clinician in the group performing the activity.
The Promoting Interoperability category remains predominantly the same. However, the “performance only” scoring methodology has most individuals and groups earning lower scores. Many have been challenged by the Health Information Exchange (HIE) measures, the timeliness aspect of providing patients access to their health data on the portal, or have forgotten to perform their Security Risk Analysis. Try to accomplish these measures as soon as possible to avoid scrambling toward the end of the year.
Understand your historical Cost data. Interpret your feedback reports, which are available for download in the Quality Payment Program portal. Try to see what aspects of cost you can influence or change. This category is notoriously confusing for people, and the two main cost measures have had important attribution and methodology changes for the 2020 program year. Do your best to wrap your head around how you will score.
No matter how you slice it, MIPS is not just about you EHR. Like any resolution you will need resources. This may include staff support, registries or other technology, billing support, MIPS program education, and/or a consultant with proven results.
Hard work will pay off
The incentives for the 2020 performance year are anticipated to be the highest yet. Due to the budget neutrality of the program and the expectation for more clinicians and practices to be penalized each year, those who perform well, will be rewarded handsomely.
If you have waited to work on MIPS in years past and intend to repeat that pattern, you are HIGHLY likely doomed to incur a penalty.
With the new year, you have an opportunity to put new habits in place to reach your MIPS goals. Just as with any resolution, it will take time and a commitment to making incremental improvements. Your hard work will pay off.