On Nov. 1, 2018, CMS issued the Calendar Year 2019 Quality Payment Program (QPP) Final Rule for the third transition year. Here are some key takeaways that will help radiologists who are participating in either the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models.
New Payment Adjustment
The third transition year increases the potential MIPS payment adjustments to +/- 7% for payment year 2021. These policies became effective on Jan. 1, 2019.
Third Criterion for MIPS Eligibility
CMS added a third criterion for determining MIPS eligibility with respect to the low-volume threshold. To be excluded from MIPS in 2019, clinicians or groups will need to meet one of the following three criteria:
- Have ≤ $90K in Part B allowed charges for covered professional services; OR
- Provide care to ≤ 200 Part B beneficiaries; OR
- New: Provide ≤ 200 covered professional services under the Medicare Physician Fee Schedule
Physicians or groups that exceed one, but not all, of the low-volume criteria can now opt-in to MIPS participation in order to receive a payment adjustment.
Updates to Category Weights
CMS has finalized an increase in the Cost category to 15% of the overall performance score, while the Quality category will be reduced to 45%. The Promoting Interoperability and Improvement Activities categories will remain at 25% and 15% respectively. CMS has increased the MIPS performance threshold for neutral adjustments from 15 to 30 points in 2019.
CMS will maintain the 60% data completeness threshold for Qualified Clinical Data Registries (QCDRs), EHRs and claims-based data submissions (with the expectation that this threshold will increase over time). Measures that do not meet data completeness will receive one point in the 2019 MIPS performance period.
CMS defines a topped-out measure as one with a median performance score of 95% or higher and a performance “so high and unvarying that meaningful distinctions and improvement in performance can no longer be made.”
Starting with the 2018 performance year and continuing through 2019 and beyond, measures identified as topped-out for two or more consecutive years will be eligible for no more than seven points.
Measures Finalized for Removal
Two measures reportable by diagnostic radiologists have been finalized for removal:
- Optimizing Patient Exposure to Ionizing Radiation: Utilization of a Standardized Nomenclature for Computed Tomography (CT) Imaging (#359)
- Optimizing Patient Exposure to Ionizing Radiation: Search for Prior CT Studies through a Secure, Authorized, Media-Free Shared Archive (#363)
There are no changes to the eligibility of non-patient-facing clinicians. For the 2019 MIPS performance year, non-patient-facing status will again be extended to individual MIPS-eligible clinicians who bill 100 or fewer patient-facing encounters (including Medicare telehealth services) during the non-patient-facing determination period.
Considerations for Small Practices
The small practice bonus score, which in previous years had been an addition of five points to a group’s or individual’s final MIPS score, has been changed to a bonus of six points added to the Quality performance category score. CMS defines small practices as 15 or fewer clinicians.