Beginning with performance year 2019 the stakes increase significantly in the MIPS program. This year it is ten times (10x) harder to avoid the penalty. To make matters worse, practices need to perform well in at least two categories to stay neutral or earn a positive adjustment.
The Quality category is continuously decreasing in weight as the Cost category increases in weight. Although the Quality category was weighted less in prior years, due to the adjustment rate, the value of the Quality category continues to rise. As the value of the Quality category rises, so does the importance of earning a higher CPS. Ultimately, the MIPS payment adjustment is budget-neutral, so the dollars available for incentives will always be funded by penalties. The exceptional performance bonus is outside of budget neutrality. For those practices that reach the 75-point threshold or higher in 2019, they will earn a much greater incentive payment.
A score of less than 30 CPS points will result in a penalty up to 7% in 2019. A score between 30 and 74 will result in a scaled payment adjustment between 0% to 0.89%, and a score of 75 or higher the incentive rate climbs dramatically to an estimated 4.69% with scaling for a perfect 100 score.
Practices can’t avoid the penalty by submitting minimal data. Submitting Improvement Activities and earning full points will only result in 15 points. This strategy would have avoided the penalty in prior years, however moving forward this will no longer be enough. Practices will need at least 15 points from other categories, to avoid the 7% penalty.
The Quality category has a 60% data completeness requirement. Practices meeting the data completeness requirement and reporting the full 6 measures will earn a minimum of 3 points per measure with no performance. This results in 18 achievement points but once re-weighted to the quality category weight of 45% the practice will only earn 13.5 points in the Quality category. If submitted along with the full 15 points earned for Improvement Activities the practice will be paying the 7% penalty with a score of only 28.5.
So what if you do well in at least one measure and can earn at least 5 points on one of the 6 measures to reach the 15 needed points in your second category?
This is not a good strategy
CMS has removed benchmarks during the performance period and changed benchmarks after submission in prior years. ”Just skating by” on one or two measures is a gamble on your final score and on the penalty. As the penalty continues to increase and thresholds become harder to meet in the MIPS program, practices need to have a thought-out strategy in place and not chance their financial impact.
We have a solution
Clients choose ReportingMD for our rock-solid history of reporting accuracy, compliance, and skilled advisory services. In its 16-year history, ReportingMD has 100% reporting accuracy and never had a submission rejected by CMS or any other payer. ReportingMD can calculate, track and report on all 400+ measures across the Quality, IA and PI categories.
ReportingMD’s solutions and services are amplified by our technical expertise, which allows us to merge and mine all of your relevant practice data assets. We are ready to receive data from any system.
ReportingMD is a Qualified Registry (QR) and a Qualified Clinical Data Registry (QCDR) and has an ONC certified EHR application for CMS reporting and submission. This makes us uniquely positioned to help you establish and manage the reporting framework for your organization.
At ReportingMD we provide measure driven outcome management solutions called Total Outcomes Management (TOM™). Using TOM™, providers have operational visibility into the clinical outcomes within their patient populations to help improve care across the healthcare continuum.
Our clients engage ReportingMD’s technology, backed by our expert support, to improve population health outcomes, optimize clinical performance score and enhance revenue.