On July 29, 2019, CMS released the 2020 Medicare Physician Fee Schedule (MPFS) proposed rule. The rule describes changes to payment provisions starting Jan. 1, 2020. In addition, it discusses policies for implementation of the fourth year for the Quality Payment Program (QPP).
The proposed rule has a 60-day comment period ending on Sept. 27, 2019. The ACR® will submit comments on the 2020 MPFS proposed rule to CMS by the due date.
ACR Releases Detailed Summary of the 2020 MPFS Proposed Rule
The ACR created a detailed summary of the 2020 MPFS proposed rule, and here are 12 key takeaways that will potentially impact radiologists in the coming year.
- Quality Payment Program
The fourth year increases the 2019 Merit-based Incentive Payment System (MIPS) payment adjustments to +/- 9% in payment year 2022. Of note, CMS is proposing to lower the weight of the quality performance category to 40% and raise the cost category to 20% of the overall performance score for performance year 2020. CMS proposes to raise the performance threshold to 45 points (from 30 in 2019) and raise the exceptional performance bonus threshold to 80. Small practices will still be able to claim the small practice bonus of 6 points to their quality score.
- MIS Value Pathways
CMS acknowledged concerns from clinicians and stakeholders about the complexity, burden, lack of performance comparability, questionable meaningfulness and lack of patient-focused measurement within the MIPS program. To address those complexities, CMS is proposing the MIPS Value Pathways (MVPs), a conceptual participation framework for future proposals beginning with the 2021 performance year. CMS’ goal with the MVP is to align measures across the “siloed” MIPS categories to make for a more meaningful and relevant assessment of a clinician’s practice.
- MIPS Performance Threshold and Incentive Payments
For the 2019 MIPS performance year, CMS set the MIPS performance threshold at 30 points and is proposing to increase it to 45 points for 2020 MIPS performance year and 60 points for 2021 MIPS performance year. Additionally, CMS proposes to increase the exceptional performance bonus threshold to 80 points for the 2020 MIPS performance year and 85 points for the 2021 MIPS performance year. CMS is moving forward with increasing the minimum MIPS penalties and maximum MIPS base incentives from -7%/+7% in 2019 to +9%/-9% in 2020.
- MIPS Category Weighting
CMS has proposed to increase the weight of the cost category under MIPS for 2020 to 20%, lower the quality category weight to 40% and maintain the weights for promoting interoperability and improvement activities categories at 25% and 15% respectively.
- Quality Category
In addition to lowering the Quality category’s weight to 40% for the 2020 performance year, CMS outlines its plan to lower the weight to 35% in 2021 and finally 30% in 2022. CMS also proposes to establish a guideline for removing Quality measures that do not meet the case minimum and reporting volume required for benchmarking after two consecutive years in the MIPS program.
- Topped-out Measures
In 2019, CMS finalized the proposal that once a measure reaches extremely topped-out status (a measure with a mean performance between the 98th and 100th percentile), CMS would propose the measure for removal during the next cycle. Nine radiology and radiology-adjacent measures have been proposed for removal beginning in the 2020 MIPS program year. See the summary document for a list of those measures.
- Quality Scoring
CMS would like to continue to award three points for each quality measure that meets data completeness, meets the case minimum of 20 cases and can be scored against a benchmark. Measures that do not have a benchmark or meet the case minimum requirement but do meet data completeness will also continue to receive three points.
- Data Completeness Requirements
CMS is proposing to raise the data completeness standard to 70% for quality measure data submission for performance year 2020. Starting in 2020, CMS intends to award zero points for measures that do not meet data completeness, but will continue to award three points to small practices.
- Improvement Activities
CMS has proposed to make a significant change to improvement activity (IA) reporting requirements for group reporters. Previously, groups could report an IA as long as one member of the group had completed that IA. For 2020, CMS is proposing to raise that requirement to at least 50% of the group within the same continuous 90-day period. Under the proposed rule, the seven medium-weighted IAs related to the ACR R-SCAN program will continue to be available.
- Proposed Cost Measures
CMS is proposing to move forward with the inclusion of ten new episode-based cost measures for implementation in 2020. See the summary document for a list of those measures.
- Virtual Groups
No major changes have been proposed for virtual groups participating in MIPS, but CMS has proposed to allow virtual groups to be considered “hospital-based” as long as 75% or more of the group’s clinicians meet the hospital-based MIPS eligible clinician designation.
- Physician Compare
CMS is proposing to begin reporting MIPS eligible physicians’ overall MIPS final scores and individual performance category scores on the Physician Compare website, as well as aggregate MIPS data showing the range of overall MIPS performance scores and individual category scores.