2019 Quality Payment Program – Final Rule

The Quality Payment Program (QPP), established by MACRA, is a payment incentive program that rewards eligible clinicians based on standards of quality and value. Changes have been made to the QPP’s Merit-based Incentive Payment System (MIPS) for the 2019 reporting year, affecting all those who participate in the MIPS program. MIPS performance assessment is split into four categories in which clinicians submit data and are assessed. The assessment categories are: Quality, Improvement Activities, Promoting Interoperability (formerly Accountable Care Information), and Cost. Each category weighs differently into the overall performance score.

Summary of 2018 Requirements

The policies and performance categories for 2018 were built upon those of the previous year. The second year of the program continued to minimize clinician burden, coordinate efficient care, and ensure meaningful processes and outcomes. Last year’s performance category weights were as follows: Quality = 50%, Improvement Activities = 15%, ACI = 25%, and Cost 10%. Combined, these four categories determine the comprehensive assessment score which determines if participating clinicians will receive either a 5% increase or decrease in their payment outcome in 2020 based on the 2018 assessment. Below is a table outlining the point values earned in the assessment and the corresponding adjustment to the payment received in 2020:

Also new last year, the performance threshold was raised to 15 points in the 2018 reporting year. Bonus points were available for clinicians treating complex patients (5 points), being a small practice (5 points), and using 2015 technology when using the 2014 and/or 2015 CEHRT. Virtual groups were included as a participation option for the 2018 reporting year and a policy for situations of extreme and uncontrollable circumstance was put in place. Outline for 2019

The final rule, to take effect January 1, 2019, updates the processes and requirements of the Merit-based Incentive Payment System (MIPS) and the Alternative Payment Model (APM). The final rule marks the full implementation of the QPP program that has been phased in over the last few years. The following are highlights of the updates for the 2019 reporting year.

The definition of Eligible Clinicians (ECs) is expanded to include additional clinician types including physical and occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and dietitians or nutrition specialists.

There will be a third element added to the low-volume threshold that will allow ECs who meet one or two standards of the low-volume threshold to opt in to participate in MIPS. The new standards for this threshold are: bills $90,000 or less in Medicare Part B, sees 200 or fewer Medicare beneficiaries, or provides 200 or fewer covered professional services under PFS. ECs meeting one or two of these criteria wishing to opt-in can do so on the QPP portal.

ECs participating in the QPP will still be scored 1-100 points based on data in these four performance categories:

Quality (45 points) – ECs must report at least six quality measures for at least 60% of applicable patient encounters (a minimum of 20 cases). Measures that meet a 60% data completeness threshold will receive a minimum score of three points. CMS permits ECs to report quality measures using multiple data collection types, but limits claim-based reporting to small practices. The final rule adds 10 new quality measures, removes 34 quality measures, and continues the rules for “topped out” measures. The reporting period for the quality category is 12 months.

Promoting Interoperability (25 points) – Previously known as “Advancing Care Information,” Promoting Interoperability is using performance-based scoring for each measure. This differs from the use of base, performance, and bonus scoring from previous reporting years. ECs report measures from four objectives and the scores for each measure will be added to determine the overall category score up to 100 points. Two new measures in this category are optional for 2019 and 2020, but ECs will earn up to five bonus points for each measure should they choose to report them. The hardship exemption still stands in this category and is expanded to include the new clinician types listed above. The reporting period for this category is 90 consecutive days.

Cost (15 points) – The weight of this category was increased from 10% to 15% of the final MIPS score in 2019. The cost category continues to assess ECs based on Total Per Capita Cost and Medicare Spending Per Beneficiary. There are eight new episode-based measures that include only items and services related to the episode of care as opposed to all services provided to a patient over a given period of time.  

Improvement Activities (15 points) – ECs continue to report improvement activities as part of their MIPS assessment. The final rule includes six new improvement activities. It also modifies five of the existing activities and removes one. The reporting period for this category is 90 consecutive days.

These four categories combine to determine the comprehensive assessment score. There is still a point bonus for clinicians who treat complex patients that adds up to five bonus points. Below is a table outlining the point values earned in the assessment and the corresponding adjustment to the payment received in 2021:

An alternative to the MIPS assessment is the Advanced Alternative Payment Model (AAPM). Medicare is hoping to see more clinicians participating in APMs and is making revisions to make it easier to participate in the program and more beneficial to these eligible clinicians. Please visit the Medicare website for more information on eligibility and the requirements of this alternative program.

In Conclusion

As QPP advances into the first year of full implementation, the updated reporting requirements will be an adjustment for all participating clinicians. Yeo & Yeo Medical Billing & Consulting stays up to date on the changing requirements of the Quality Payment Program. Please call us with questions or concerns you may have regarding your QPP reporting and assessments.

For additional resources, visit the following websites:

https://qpp.cms.gov/

https://www.qppresourcecenter.com