As the 2019 reporting year draws to a close, practices are focused on ensuring that all 2019 data is ready for submission and primed to earn the highest possible score for maximum incentives. What may not be on their minds is the next, or even subsequent, reporting year(s). It’s time to direct attention toward the future and begin planning for MIPS 2020 and beyond.
With the November release of the 2020 Quality Payment Program Final Rule, most of the necessary information is available to begin planning for future reporting. Topics to consider now are: reporting category changes, retired/substantially changed measures. Prior to January 1, 2020 CMS will release the Quality measure benchmarks at which point practices should begin making decisions on which measures they plan to report for 2020.
For the MIPS quality category, there are multiple items to consider when making measure selection, and the sooner the decisions are made, the sooner processes and procedures can be set to perform well on those measures. If any of the quality measures that a practice reported on in 2019 are being removed, then they may need to select new measure(s) and implement new processes and procedures across the practice to ensure high performance. The same scenario applies to measures that lose their benchmark or measure value by being topped out or capped in future years.
For the MIPS Improvement Activities category, the final rule established a major change in reporting requirements for the 2020 reporting year. In performance year 2019 and prior it was only required that one MIPS eligible clinician in the practice perform an activity for a continuous 90-day window. Beginning in performance year 2020, it is required that at least 50% of the clinicians in the practice must participate in an improvement activity for the group to earn the credit. This category is worth up to 15 points of the total MIPS score, so without these points it could be the difference of whether a practice reaches the exceptional performance threshold, which is a significant difference in payment adjustment.
It is known that each year the penalty becomes harder to avoid. In 2020 a practice must earn 45 points to avoid the penalty, and in 2021 this threshold will increase to 60 points to avoid penalty. Planning ahead by selecting measures and enacting processes and procedures ahead of time allows for a much higher likelihood of success. Other significant changes to the MIPS program also need time for planning, such as the change in Improvement Activity participation and the proposed MIPS Value Pathways (MVPs).
The MIPS Value Pathway is an entire programmatic change that is to start in 2021. This is a new framework that will move closer towards an aligned set up measure options more relevant to a clinician’s specialty. This framework would align measures from all four of the MIPS performance categories; Quality, Improvement Activities, Promoting Interoperability and Cost. It would be wise to begin planning for this change while selecting measures and activities for 2020.
Waiting until 2020 has begun, or even procrastinating further into the 2020 performance year to prepare for MIPS will likely result in poor scores and minimal incentive, or even possible penalizations. Start planning now for MIPS 2020 and beyond.