MIPS 2020 and 2021 Final Rule

CMS recently posted the Final Rule for MIPS for 2020 and 2021. What does this mean for you as a MacPractice Office and what changes should you expect?

The Centers for Medicare and Medicaid Services (CMS) has released its proposed rule for the Quality Payment Program (QPP), with several proposed changes to MIPS in 2020 and future reporting years. A final rule will be released later this Fall after a public comment period. The proposed rule would continue to gradually increase the reporting requirements under the MIPS program.


Main Points to takeaway: 

CMS has changed the performance thresholds. (The number of MIPS points needed to avoid penalties.)

  • 2019 - 30 points
  • 2020 - 45 points
  • 2021 - 60 points

With the penalty increasing from -7% in 2019 to -9% in 2020.

Category Weights:

Will remain the same for 2020:

Quality Cost Promoting interoperability Improvement Activities
45% 15% 25% 15%

Things that are not changing in 2020:

Performance Period: The performance period for all performance categories will remain same as performance year 2019.

  • Quality and Cost - Full calendar year (Jan 1, 2020 - Dec 31, 2020)

  • PI and IA - Minimum of 90 continuous days within the performance year

Low Volume Threshold (LVT) and Opt-In: Same criteria will apply for determining the LVT as well as for clinicians to opt-in.

  1. Bill > $90,000 in Medicare Part B allowed charges AND

  2. Provide care to > 200 Medicare Part B beneficiaries AND

  3. Provide >200 covered professional services

Scoring Methodologies: Same scoring policies will apply for measures, activities, and performance category scoring including the 3 point floor for scored measures, improvement scoring, small-practice bonus, high-priority measures, and end-to-end electronic reporting bonus.

Quality Measures:

  • Removed or topped out several Quality measures.
  • Added new specialty sets for Speech Language Pathology, Audiology, Clinical Social Work, Chiropractic Medicine, Pulmonology, Nutrition/Dietician, and Endocrinology.
  • Established flat percentage benchmarks for limited cases where CMS determines that the measure’s benchmark could potentially incentivize inappropriate treatment for some patients.

Facility-Based Clinicians: The definition and determination of Facility-based clinicians along with the scoring methodology will remain unchanged from 2019.

Collection and Submission of Data: All the collection types available for data submission in the performance year 2019 are proposed for 2020 too, that is eCQMs(EHR Measures), MIPS CQMs (Registry measures), QCDR measures, CAHPS for MIPS survey, and CMS Web Interface measures. How eligible clinicians can submit data to CMS is also proposed to stay intact including Direct, log in and upload, log in and attest, Medicare Part B claims and the CMS Web Interface.


MIPS 2021 Value Pathways 

They have also adopted a new framework for 2021 called MIPS Value Pathways (MVP) CMS created some illustrative diagrams regarding the MIPS Value Pathways:

MIPS Value Pathways Diagram

MIPS Value Pathways Diabetes Example

MIPS Value Pathways Surgery Example


Moving Forward:

What does this all mean for your office? More reporting and planning will be necessary to avoid any penalties.

Keep in mind that these are all just proposals for now and a final rule should be in place by Fall 2019.

More information can be found here.

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