CMS Releases 2020 MIPS Proposed Rule

If you’re participating in MIPS, you’ll need to know about the changes to the program in 2020. This week, CMS released the Quality Payment Program proposed rule for the next performance year. While their goal is to maintain many of the requirements from the 2019 performance year, there are some updates to the MIPS track. Here are the highlights of the proposed changes.

Quality and Cost performance category weights

In 2020, the Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.

Payment adjustment

The maximum negative payment adjustment will increase from -7% to -9% in 2020. Positive payment adjustments (not including exceptional performance) will increase from 7% to up to 9%.

Performance threshold

The performance threshold–the minimum number of points to avoid a negative payment adjustment–will increase from 30 points in 2019 to 45 points in 2020. The exceptional performance threshold, which determines additional positive payment adjustments, will increase to 80 points in 2020.

A full breakdown of proposed MIPS changes can be found in the table below. CMS is accepting feedback on the proposed rule at regulations.gov through September 27, 2019 with the file code CMS-1715-P.

CMS has also proposed larger changes to the program starting in 2021. Click here to read our summary of their new proposed framework.

For more information on the current MIPS performance year and how SurveyVitals can help you fulfill your requirements, visit our MIPS page or chat with us using the blue chat icon below.

Policy Area Current Year 3 (Final Rule CY 2019) Year 4 (Proposed Rule CY 2020)
Performance Category Weights
  • Quality: 45%
  • Cost: 15%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%
  • Quality: 40%
  • Cost: 20%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%
Quality Performance Category Data Completeness Requirements
  • Medicare Part B Claims measures: 60% of Medicare Part B patients for the performance period
  • QCDR measures, MIPS CQMs, and eCQMs: 60% of clinician’s or group’s patients across all payers for the performance period
Call for Measures
CMS seeks measures that are:
  • Applicable
  • Feasible
  • Reliable
  • Valid at the individual clinician level
  • Different from existing measures
Measure Removal
  • A quality measure may be considered for removal if the measure is no longer meaningful, such as measures that are topped out
  • A measure would be considered for removal if a measure steward is no longer able to maintain the quality measure
QCDR Measure Requirements
  • QCDR measures must be beyond the measure concept phase of development
  • CMS will show a preference for QCDR measures that are outcome-based rather than clinical process measures
  • Measures should address significant variation in performance
  • QCDR measures are approved for use in MIPS for a single performance period
Measure Removal
There is no formal policy for measure removal, as QCDR measures must be submitted for CMS approval on an annual basis as part of the self-nomination process.
Data Completeness Requirements
  • Medicare Part B claims measures: 70% sample of Medicare Part B patients for the performance period
  • QCDR measures, MIPS CQMs, and eCQMs: 70% sample of clinician’s or group’s patients across all payers for the performance period
  • Note: If quality data is submitted selectively such that the data are unrepresentative of a MIPS eligible clinician or group’s performance, any such adat would not be true, accurate, or complete
Call for Measures
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
Measure Removal
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
  • We may consider a MIPS quality measure for removal if we determine it is not available for MIPS Quality reporting by or on behalf of all MIPS eligible clinicians (including via third party intermediaries)
QCDR Measure Requirements
In instances in which multiple, similar QCDR measures exist that warrant approval, we may provisionally approve the individual QCDR measures for 1 year with the condition that QCDRs address certain areas of duplication with other approved QCDR measures in order to be considered for the program in subsequent years. Duplicative QCDR measures would not be approved if QCDRs do not elect to harmonize identified measures as requested by CMS within the allotted timeframe.

QCDR Measure Rejections
CMS is proposing the following guidelines to help QCDRs understand when a QCDR measure would likely be rejected during the annual self-nomination process:

  • QCDR measures that are duplicative of an existing measure or one that has been removed from MIPS or legacy programs
  • Existing QCDR measures that are “topped out” (though these may be resubmitted in future years)
  • QCDR measures that are process-based (consideration given to the impact on the number of measures available for a specific specialty) or have no actionable quality action
  • Considerations and evaluation of the measure’s performance data, to determine whether performance variance exists
  • QCDR measures that have the potential for unintended consequences
  • QCDR measures that split a single clinical practice/action into several measures or that focus on rare events
  • QCDR measures that are “check-box” with no actionable quality action
  • Existing QCDR measures that have been in MIPS for two years and have failed to reach benchmarking thresholds due to low adoption (unless a plan to improve adoption is submitted and approved)
  • Whether the existing approved QCDR measure is no longer considered robust, in instances where new QCDR measures are considered to have a more vigorous quality action, where CMS preference is to include the new QCDR measure rather than requesting QCDR measure harmonization
  • QCDR measures with clinician attribution issues, where the quality action is not under the direct control of the reporting clinician. (that is, the quality aspect being measured cannot be attributed to the clinician or is not under the direct control of the reporting clinician)
  • QCDR measures that focus on rare events or “never events” in the measurement period
Improvement Activities Performance Category Definition of Rural Area
Rural area means a ZIP code designated as rural, using the most recent Health Resources and Services Administration (HRSA) Area Health Resource File data set available.

Patient-Centered Medical Home Criteria
To be eligible for Patient-Centered Medical Home designation, the practice must meet one of the following criteria:

  • The practice has received accreditation from one of four accreditation organizations that are nationally recognized:
    • The Accreditation Association for Ambulatory Healthcare
    • The National Committee for Quality Assurance (NCQA)
    • The Joint Commission
    • The Utilization Review Accreditation Commission (URAC); OR
  • The practice is participating in a Medicaid Medical Home Model or Medical Home Model; OR
  • The practice is a comparable specialty practice that has received the NCQA Patient Centered Specialty Recognition
Improvement Activities Inventory
  • Added 1 new criterion, “Include a public health emergency as determined by the Secretary”
  • Removed “Activities that may be considered for a Promoting Interoperability bonus”
CMS Study on Factors Associated with Reporting Quality Measures
MIPS eligible clinicians who successfully participate in the study receive full credit in the Improvement Activities performance category.

Removal of Improvement Activities
No formal policy but invited public comments on what criteria should be used to identify improvement activities for removal from the inventory.

Requirement for Improvement Activity Credit for Groups
Group or virtual group can attest to an improvement activity if at least one clinician in the TIN participates.

Definition of Rural Area
Rural area is proposed to mean a ZIP code designated as rural by the Federal Office of Rural Health Policy (FORHP) using the most recent FORHP Eligible ZIP Code file available.

Patient-Centered Medical Home Criteria
To be eligible for Patient-Centered Medical Home designation, the practice would need to meet one of the following criteria:

  • The practice has received accreditation from an accreditation organization that is nationally recognized
  • The practice is participating in a Medicaid Medical Home Model or Medical Home Model
  • The practice is a comparable specialty practice that has received recognition through a specialty recognition program offered through a nationally recognized accreditation organization; OR The practice has received accreditation from other certifying bodies that have certified a large number of medical organizations and meet national guidelines, as determined by the Secretary. The Secretary must determine that these certifying bodies must have 500 or more certified member practices, and require practices to include the following:
    1. Have a personal physician/clinician in a team-based practice
    2. Have a whole-person orientation
    3. Provide coordination or integrated care
    4. Focus on quality and safety
    5. Provide enhanced access
Improvement Activities Inventory
  • Addition of 2 new Improvement Activities
  • Modification of 7 existing Improvement Activities
  • Removal of 15 existing Improvement Activities

Please review Appendix 2 in the CY 2020 NPRM for a comprehensive look at the changes proposed to the inventory.

CMS Study on Factors Associated with Reporting Quality Measures
Study year 2019 (CY 2019) is the last year of the 3-year study, as stated in CY 2019 PFS final rule (83 FR 59776). CMS will not continue the study during the 2020 performance period. Final study results will be shared at a later date.

Removal of Improvement Activities
Establish factors to consider for removal of improvement activities from the Inventory. An activity would be considered for removal if:

  • It is duplicative of another activity
  • An alternative activity exists with stronger relationship to quality care or improvements in clinical practice
  • The activity does not align with current clinical guidelines or practice
  • The activity does not align with at least one meaningful measures area
  • The activity does not align with Quality, Cost, or Promoting Interoperability performance categories
  • There have been no attestations of the activity for 3 consecutive years
  • The activity is obsolete
Requirement for Improvement Activity Credit for Groups
  • Group or virtual group would be able to attest to an improvement activity when at least 50% of MIPS eligible clinicians (in the group or virtual group) participate in or perform the activity
  • At least 50% of a group’s NPIs must perform the same activity for the same continuous 90 days in the performance period
Promoting Interoperability Performance Category – Hospital-Based MIPS Eligible Clinicians in Groups

A group is identified as hospital-based and eligible for reweighting when 100% of the MIPS eligible clinicians in the group meet the definition of a hospital-based MIPS eligible clinician.

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) we would automatically reweight the Promoting Interoperability performance category.

No change to definition of an individual hospital-based MIPS eligible clinician.

Promoting Interoperability Performance Category Objectives and Measures
  • One set of objectives and measures based on the 2015 Edition CEHRT
  • Four objectives: ePrescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange
  • Clinicians are required to report certain measures from each of the four objectives, unless an exclusion is claimed
  • PTwo new measures for the e-Prescribing objective: Query of Prescription Drug Monitoring Program (PDMP) and Verify Opioid Treatment Agreement as optional with bonus points available
Objectives and Measures
  • CMS would 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
Cost Performance Category Measures
  • Total Per Capita Cost (TPCC)
  • Medicare Spending Per Beneficiary (MSPB)
  • 8 episode-based measures
Case Minimums
  • 10 for procedural episodes
  • 20 for acute inpatient medical condition episodes
Measure Attribution
  • All measures are attributed at the TIN/NPI level for both individuals and groups
  • Plurality of primary care services rendered by the clinician to determine attribution for the total per capita cost measure
  • Plurality of Part B services billed during the index admission to determine attribution for the MSPB measure
  • For procedural episodes, we attribute episodes to each MIPS eligible clinician who renders a trigger service (identified by HCPCS/CPT procedure codes)
  • For acute inpatient medical condition episodes, we attribute episodes to each MIPS eligible clinician who bills inpatient evaluation and management (E&M) claim lines during a trigger inpatient hospitalization under a TIN that renders at least 30% of the inpatient E&M claim lines in that hospitalization
Measures
  • TPCC measure (Revised)
  • MSPB-C (MSPB Clinician) measure (Name and specification Revised)
  • 8 existing episode-based measures
  • 10 new episode-based measures
Case Minimums
No changes.

Measure Attribution
  • Measure attribution would be different for individuals and groups and would be defined in the measure specifications
  • TPCC attribution would require E&M services to have an associated primary care service or a follow up E&M service from the same clinician group
  • TPCC attribution would exclude certain clinicians who primarily deliver certain non-primary care services (e.g. general surgery)
  • MSPB clinician attribution changes would have a different methodology for surgical and medical patients
  • No changes proposed for attribution in episode-based measures (existing and new)
Final Score Calculation: Performance Category Reweighting due to Data Integrity Issues
  • No policy to account for data integrity concerns
  • Several scenarios for reweighting have previously been finalized, including extreme and uncontrollable events (all performance categories) and hardship exemptions specific to the Promoting Interoperability performance category
  • We would reweight performance categories in rare events due to compromised data outside the control of the MIPS eligible clinician. MIPS eligible clinicians or third party intermediaries can inform CMS that they believe they are impacted by a relevant event by providing information on the event (CMS may also independently learn of qualifying events)
  • If we determine that reweighting for compromised data is appropriate, we would generally redistribute to the Promoting Interoperability performance category as well as the Quality performance category
  • In rare cases, we would redistribute to the Cost performance category
Performance Threshold / Additional Performance Threshold / Payment Adjustment
  • Performance Threshold is set at 30 points
  • Additional performance threshold set at 75 points for exceptional performance
  • As required by statute, the maximum negative payment adjustment is – 7%
  • Positive payment adjustments can be up to 7% (not including additional positive payment adjustments for exceptional performance) but are multiplied by a scaling factor to achieve budget neutrality, which could result in an adjustment above or below 7%
  • Performance Threshold would be set at 45 points
  • Additional performance threshold would be set at 80 points for exceptional performance
  • As required by statute, the maximum negative payment adjustment is -9%
  • Positive payment adjustments can be up to 9% (not including additional positive adjustments for exceptional performance) but are multiplied by a scaling factor to achieve budget neutrality, which could result in an adjustment above or below 9%
Targeted Review

MIPS eligible clinicians and groups may submit a targeted review request by September 30 following the release of the MIPS payment adjustment factor(s) with performance feedback.

All requests for targeted review would be required to be submitted within 60 days of the release of the MIPS payment adjustment factor(s) with performance feedback.

Schedule a Demo

Share This Article: Share on FacebookTweet about this on TwitterShare on LinkedInEmail this to someone

July 30th, 2019 Categories: featured, MIPS Information, Patient Experience

Tags: , , , , , , , , ,

Recent Posts

Provider Spotlight: Tina Eide, MD, Matrix Anesthesia
September 16, 2019

Tina Eide, a board certified anesthesiologist from Matrix Anesthesia, was one of the winners of our recent Patient Experience Week giveaway. We asked Tina about the best practices she follows to provide exceptional patient care, and we’re excited to share her responses. Tina studied medicine at the University of Washington and trained at Virginia Mason […]

Feature Highlight: Challenge Mode
September 9, 2019

Have you set up a challenge yet? Using Challenge Mode, you can create a competition between your providers to encourage improvement. Once the competition is live, you can monitor the results in real-time from your dashboard. During Challenge Mode setup, choose questions or question areas you want to focus on. At the end of the […]

Surveys You Might Not Know SurveyVitals Offers
August 28, 2019

SurveyVitals’ digital patient experience surveys help you gain a deeper understanding of your performance with immediate patient feedback. Did you know our solution includes many more surveys at no additional cost to help drive improvement from every angle of your practice? 1. Point of Care Our Point of Care tool allows you to address patient […]

patient experience benefits
5 Benefits of Higher Patient Experience Scores
August 20, 2019

Today, there’s a bigger emphasis on the patient experience than ever–and for good reason. Here are five reasons you should want to achieve higher patient experience scores. 1. A better patient experience often leads to better outcomes Numerous studies have shown a correlation between positive patient experience and better health outcomes. The patient experience is […]