NEPHROLOGY TODAY BLOG
Emily Frederick Podcast interview with Sandeep Bajaj MD, Quality Programs Expert at Tower
Starting in Year 3 of the MIPS program, CMS will add a 3rd criterion for clinicians to qualify for the low-volume threshold. Clinicians and groups must meet one of the following three criteria to be excluded from MIPS:
● Have $90,000 or less in Part B allowed charges for covered professional services; OR
● Provide care to 200 or fewer beneficiaries; OR
● New: Provide 200 or fewer covered professional services under the Physician Fee Schedule (PFS).
MIPS eligibility includes only those eligible clinicians in the categories below who bill for Medicare Part B (otherwise known as the Physician Fee Schedule) or Critical Access Hospital (CAH) Method II payments assigned to the CAH.
The eligibility net expands over the first several years as follows:
● 2017 and 2018 performance years: physicians (MD/DO and DMD/DDS), physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists
● Additions for 2019 performance year: expanded to physical and occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutrition professionals
● Applicable payments for MIPS adjustments: For performance year 2019, Part B payments for services are subject to MIPS payment adjustments (excludes payments for items, such as Part B drugs).
● Excluded Payments:
○ Medicare Part A
○ Medicare Advantage Part C
○ Medicare Part D
○ CAH Method I facility payments
○ Federally qualified health center (FQHC), rural health clinic (RHC), ambulatory surgical center (ASC), home health agency (HHA), hospice, or hospital outpatient department (HOPD) facility payments billed under the facility’s all-inclusive payment methodology or prospective payment system methodology
For the 2019 performance year, and for individual clinicians or groups of clinicians billing through a common tax identification number (TIN) meeting the above eligibility criteria, there are only three exclusions from MIPS:
● Clinicians in their first calendar year of Medicare Part B participation
● “Low-volume exclusion”: in a 12-month period, clinicians or groups each (a) billing $90,000 or less in Medicare Part B allowed charges for services, (b) providing care for 200 or fewer Part B beneficiaries, or (c) delivering 200 or fewer covered services to Part B beneficiaries
What are the Performance Periods for MIPS 2019?
● MIPS 2019 performance period: January 1, 2019 to December 31, 2019
● Quality and Cost performance categories: 12-month period
● Improvement Activities (IA) and Promoting Interoperability (PI) performance categories: minimum continuous 90-day period
● Deadline for submitting MIPS 2019 data: March 31, 2020
● CMS provides MIPS 2019 reporting performance feedback to ECs: July 2020
● MIPS payment adjustments (positive, negative or neutral) are applied to each claim: starts January 1, 2021
MIPS is a catalyst to move healthcare providers toward value-based payment models. The 2019 QPP Final Rule signals additional changes in the coming years that will further amplify the program:
● Continuing to increase the performance threshold by about 15 points per year, towards being above 65 points by 2022
● Continuing to increase the Cost category weight by 5% per year, towards 30% by 2022, as required by law
● Adding more episode-based cost measures
● Removing quality bonus points for high-priority measures and end-to-end electronic reporting
● Reducing bonus measures in the PI category
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