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2019 MIPS Performance Weightage

2019, being the third performance year of the MIPS rollout, CMS has now added 5% weight to the Cost category reducing 5% points from the Quality category, Weightage of the Quality category is reduced from:

  • 60% in 2017

    • 50% in 2018
      • 45% in 2019

The weightage for PI and IA remains the same at 25% and 15% respectively.

Performance category

Performance Category

Quality Reporting Requirements

Criteria

MIPS Quality

Measure Group Submission

Measure group submission is not allowed, instead Physicians can use specialty measure sets to ensure simplicity in reporting.

Submission Eligibility

  • Eligible clinicians can submit from the specialty measure set.
  • Groups can also submit their applicable measure sets or select the best applicable measures.

Submission Criteria

  • Individuals and Groups have to report 6 measures including one outcome measure or a high priority.
  • If specialty specific measure set has fewer than 6 measures, eligible clinicians have to report for all the applicable measures.

Data Completeness Criteria

MIPS eligible clinicians have to submit data on at least 60 percent of the MIPS eligible clinicians or group’spatient’s data regardless of the payer.

Case Volume

Minimum 20 patients per measure is required.

Performance Criteria

Quality measures submitted for the 2019 performance period will receive between 1 and 10 points as measure achievement points.
Quality measures fall into one of three categories for scoring:

  • Between 3 and 10 Points: The measure meets the data completeness criteria, has a benchmark, and the volume of cases is sufficient (> 20 cases for most measures). These measures continue to receive between 3 to 10 points based on performance compared to the benchmark.
  • 3 Points: The measure meets the data completeness criteria but either (1) doesn’t have a benchmark and/or (2) the volume of cases you’ve submitted is insufficient (<20 cases for most measures). These measures continue to receive 3 measure achievement points.
  • 1 Point:The measure doesn’t meet the data completeness criteria, which varies by collection type. These measures receive 1 point, except for small practices which would continue to receive 3 measure achievement points.

Mutiple Collection Types (Separate Criteria)

  • In Year 3, groups and virtual groups can submit measures via multiple collection types (MIPS CQM, eCQM, QCDR measures, CMS Web Interface measures for large practices, and Medicare Part B claims measures for small practices)
  • If the same measure is submitted via multiple collection types, the one with the greatest number of measure achievement points will be selected for scoring
  • EXCEPTION: CMS Web Interface measures cannot be scored with other collection types other than CMS approved survey vendor measure for CAHPS for MIPS and/or administrative claims measures.

Reporting Requirements

Quality Reporting Requirements

Criteria

MIPS Quality

Measure Group Submission

Measure group submission is not allowed, instead Physicians can use specialty measure sets to ensure simplicity in reporting.

Submission Eligibility

  • Eligible clinicians can submit from the specialty measure set.
  • Groups can also submit their applicable measure sets or select the best applicable measures.

Submission Criteria

  • Individuals and Groups have to report 6 measures including one outcome measure or a high priority.
  • If specialty specific measure set has fewer than 6 measures, eligible clinicians have to report for all the applicable measures.

Data Completeness Criteria

MIPS eligible clinicians have to submit data on at least 60 percent of the MIPS eligible clinicians or group’s patient’s data regardless of the payer.

Case Volume

Minimum 20 patients per measure is required.

Performance Criteria

Quality measures submitted for the 2019 performance period will receive between 1 and 10 points as measure achievement points.
Quality measures fall into one of three categories for scoring:

  • Between 3 and 10 Points: The measure meets the data completeness criteria, has a benchmark, and the volume of cases is sufficient (> 20 cases for most measures). These measures continue to receive between 3 to 10 points based on performance compared to the benchmark.
  • 3 Points: The measure meets the data completeness criteria but either (1) doesn’t have a benchmark and/or (2) the volume of cases you’ve submitted is insufficient (<20 cases for most measures). These measures continue to receive 3 measure achievement points.
  • 1 Point: The measure doesn’t meet the data completeness criteria, which varies by collection type. These measures receive 1 point, except for small practices which would continue to receive 3 measure achievement points.

Mutiple Collection Types (Separate Criteria)

  • In Year 3, groups and virtual groups can submit measures via multiple collection types (MIPS CQM, eCQM, QCDR measures, CMS Web Interface measures for large practices, and Medicare Part B claims measures for small practices)
  • If the same measure is submitted via multiple collection types, the one with the greatest number of measure achievement points will be selected for scoring
  • EXCEPTION: CMS Web Interface measures cannot be scored with other collection types other than CMS approved survey vendor measure for CAHPS for MIPS and/or administrative claims measures.

PI Reporting Requirements

CMS has made only a few changes to the MIPS PI Reporting Requirements for 2019. The key requirements for MIPS PI reporting requirements are as listed below:

In 2019, There is only one measure set for reporting based on 2015 CEHRT EHR edition:

Promoting Interoperability
Objectives & Measures

PI Reporting Requirements

Promoting Interoperability

Replaces the Medicare EHR Incentive Program, also known as Meaningful Use.

PI Statements: Prevention of Information Blocking Attestation

If Clinician is a MIPS eligible clinician who reports on the Promoting Interoperability performance category he/she must attest to the prevention of information blocking attestation. If Provider is reporting as a group, the prevention of information blocking attestation by the group applies to all MIPS eligible clinicians within the group. Therefore, if one MIPS eligible clinician in the group fails to meet the requirements of the Prevention of Information Blocking Attestation, then the whole group would fail to meet the requirement.

Statement 1: A MIPS eligible clinician must attest that they did not knowingly and willfully take action (such as to disable functionality) to limit or restrict the compatibility or interoperability of CEHRT.

Statement 2: A MIPS eligible clinician must attest that they implemented technologies, standards, policies, practices, and agreements reasonably calculated to ensure, to the greatest extent practicable and permitted by law, that the CEHRT was, at all relevant times

  • Connected in accordance with applicable law.
  • Compliant with all standards applicable to the exchange of information, including the standards, implementation specifications, and certification criteria adopted at 45 CFR Part 170.
  • Implemented in a manner that allowed for timely access by patients to their electronic health information (including the ability to view, download, and transmit this information).
  • Implemented in a manner that allowed for the timely, secure, and trusted bidirectional exchange of structured electronic health information with other health care providers (as defined by 42 U.S.C. 300jj(3)), including unaffiliated providers, and with disparate CEHRT and health IT vendors.

Statement 3: A MIPS eligible clinician must attest that they responded in good faith and in a timely manner to requests to retrieve or exchange electronic health information, including from patients, health care providers (as defined by 42 U.S.C. 300jj(3)), and other persons, regardless of the requestor’s affiliation or technology vendor.

Scoring Logic:

1. MIPS eligible clinicians are required to report certain measures from each of the four objectives, with performance-based scoring occurring at the individual measure-level.

2. Each measure is scored based on the MIPS eligible clinician’s performance for that measure, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require a yes/no attestation.

3. The scores for each of the individual measures are added together to calculate the total Promoting Interoperability performance category score of up to 100 possible points for each MIPS eligible clinician.

4. To calculate the Promoting Interoperability performance category score, the measure scores are added together, and the total sum is divided by the total possible points (100). The total sum cannot exceed the total possible points. This calculation results in a fraction from zero to 1, which can be formatted as a percent.

5. For a MIPS eligible clinician to earn a score greater than zero for the Promoting Interoperability performance category, in addition to completing the actions included in the Security Risk Analysis measure, the MIPS eligible clinician must submit their complete numerator and denominator or yes/no data for all required measures.

IA Reporting Requirements

CMS has made only a few changes to the MIPS IA Reporting Requirements for 2019. The key requirements for MIPS IA reporting requirements are as listed below:

The Improvement Activities (IA) performance category focuses on one of the MIPS strategic goals, to use a patient-centered approach to program development that leads to better, smarter, and healthier care

For the performance year 2019, New Improvement Activities are finalized and previously adopted improvement activities have been updated along with the removal of a few existing activities

MIPS would reward Improvement Activities falling into Care coordination, Beneficiary engagement, and Patient safety sub-categories which MIPS eligible clinicians could select from a list of approximately 118 activities

Beginning with 2019, MIPS performance period, participants no longer require self-identifications for non-patient facing MIPS eligible clinicians, small practices, practices located in rural areas or geographic HPSA

MIPS eligible clinicians or groups can simply attest to activities performed for a continuous 90 day period and qualify for reward in IA category

Cost Reporting Requirements

CMS included Cost category in the MIPS final score in PY 2019. Cost Performance Category has a weight of 15% in the MIPS Final Score for 2019 performance period. No reporting is required for this category as CMS will be calculating this on their end.

Cost Reporting Requirements
  • Cost performance category reporting period will be for the full performance year in 2019.
  • Individual eligible clinicians or groups will be scored on ten measures included in the Cost performance category for 2019 MIPS Performance period-
  • Medicare Spending per Beneficiary (MSPB), Total per Capita Cost measure for all attributed beneficiaries (TPCC) and Eight episode-based cost measures.
  • CMS will calculate Cost category score based on MIPS eligible clinicians’ performance compared to the measure benchmark.
  • Individual MIPS eligible clinicians and groups don’t have to submit any other information for the Cost performance category.