APMA News - September/October 2019 - 40

IT Consultant
By James R. Christina, DPM; Jeffrey D. Lehrman, DPM;
and Dyane E. Tower, DPM, MPH, MS

MIPS in 2020: What You Need to Know
CMS has released its CY 2020 Medicare Physician Fee
Schedule (MPFS) proposed rule. This document contains proposed changes to the Merit-based Incentive Payment System
(MIPS) for 2020. Although it is a proposed rule open for comments (APMA has submitted comments) and the final rule may
contain changes based on APMA's comments, for now, the following is what you should be prepared for if you meet the eligibility requirements for MIPS in 2020.
The eligibility threshold numbers are not changing for 2020;
therefore, if you were required to participate in 2019 and have
not had substantial changes to your practice, you can anticipate
you will be required to participate in 2020.

Key Proposed Changes for 2020
Overall:
Increase the performance threshold (the minimum number of MIPS points you need to avoid a negative payment
adjustment) from 30 points in 2019 to 45 points in 2020
Reduce the Quality performance category weight to 40
percent in 2020
Increase the Cost performance category weight to 20
percent in 2020

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CMS is also soliciting comments on the concept of MIPS
Value Pathways ("MVPs"), which would change MIPS to make
it more cohesive and, stakeholders hope, reduce burden on
physicians. APMA submitted comments on this new concept,
including points to help ensure podiatrists are included and
have relevant pathways by which we can participate.
Aside from the MIPS performance categories, CMS is
focusing on improving partnerships with third parties. To
help reduce the clinician reporting burden, CMS is proposing to:
update policies for third-party vendors, such as Qualified
Clinical Data Registries (QCDRs) and Qualified Registries
(QRs);
establish new requirements for MIPS performance categories that must be supported by QCDRs, QRs, and
Health IT vendors;
modify criteria for approval as a third-party intermediary
by establishing new requirements to promote continuity
of service to clinicians and groups that use third-party
intermediaries for their MIPS submissions; and
clarify remedial action and termination provisions applicable to all third-party intermediaries.

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Promoting Interoperability Category:
No significant changes proposed (Note: The requirement
to use an EHR with 2015 ONC certification remains in
place.)

With respect to QCDRs, CMS is proposing requirements
to engage in activities that foster improvement in the quality
of care, and to enhance performance feedback requirements.
CMS is also proposing to update considerations for QCDR
measures, including that QCDR measures would be required
to be fully developed with completed testing results at the
clinician level and must be ready for implementation at the
time of self-nomination for the 2021 performance period.
With respect to QRs, CMS is proposing to require enhanced
performance feedback.
CMS is proposing updates for the public reporting of MIPS
performance, recognizing the importance of providing patients
with valuable information to help empower their decision-making. CMS proposes to publicly report aggregate MIPS data beginning with Year 2 (CY 2018 data, available starting in late CY
2019), as technically feasible.
More information on CMS' proposed changes to MIPS in
2020 can be found on the 2020 Quality Payment Program
Proposed Rule Overview Fact Sheet, available at http://bitly/
2TX22T4.
n

Cost Category:
Add 10 new episode-based measures and revise the current measures-Medicare Spending Per Beneficiary Clinician measure and Total Per Capita Costs measure

Contact Dr. Christina at jrchristina@apma.org, Dr.
Lehrman at jdlehrman@apma.org, and Dr. Tower at
detower@apma.org.

Quality Category:
Increase the threshold for data completeness from 60
percent of eligible patients in 2019 to 70 percent of eligible patients for 2020
Continue to remove low-bar, standard-of-care process
measures and focus on high-priority outcome measures

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Improvement Activities Performance Category:
Increase participation threshold for group reporting from
a single clinician to 50 percent of the clinicians in the
practice
Update the Improvement Activity Inventory and establish criteria for removal in the future

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40 APMA News September/October 2019
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APMA News - September/October 2019

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