• MIPS 2020—How Do Small Practices Avoid the Payment Penalty?

    Excerpted from MIPS—What’s New in 2020 for Ophthalmology (EyeNet, January 2020). Also see MIPS 2020: A Primer and Reference, which is being posted online ahead of print.


    Argus Eye Care, to give a hypothetical example, is a small cataract practice with no EHR system. Each year, its goal has been to find the least burdensome way to avoid the MIPS payment penalty.

    In 2019, it did this by 1) scoring 100% on improvement activities and 2) reporting six quality measures via Medicare Part B claims on several patients. (For a small practice, reporting each measure on one patient could have been enough, but Argus reported on several patients in case the claim for the initial patient was rejected.)

    What would the same practice have to do in 2020? One path to avoiding the penalty would involve 1) scoring 100% on improvement activities, 2) successfully applying for the promoting interoperability (PI) hardship exception, and 3) reporting more extensively on quality measures than it did in 2019. How extensively? Assuming that the practice qualifies for the PI exception, clinicians in the practice could still do minimal claims-based reporting for some quality measures (see the Academy guide to claims reporting), but the Academy recommends that they should satisfy the 70%–data completeness criteria and the 20-patient case minimum for at least two measures that can each contribute 5 or more points to their quality score.

    Note: The above scenario assumes that Argus Eye Care is scored on the cost performance category’s cataract measure, which is the only cost measure that is likely to apply to ophthalmology practices. 

    However, if Argus Eye Care is not scored on any cost measures and successfully applies for a PI exception, CMS will reallocate the weight of those two measures to quality, which would now contribute up to 85 points to its MIPS final score; in this case, the practice might be able to avoid the MIPS payment penalty by scoring 100% on improvement activities and just doing minimal reporting on six quality measures. For more information on the different scoring scenarios, see the Small Practice Roadmap.

    Important: Research quality measures carefully; review the Academy guide to reading quality measures (PDF) and make sure that you understand a measure’s specifications and confirm that it isn’t subject to significant scoring limitations. Scoring for this year’s quality measures is based on benchmarks that CMS published on Dec. 31, 2019. The Academy has summarized scoring information for the quality measures that can be reported via the IRIS Registry:

    The Academy also has summarized scoring information for the 15 claims-based measures that are most relevant to ophthalmology:

    Make sure you read the Academy Claims Reporting Guide.

    Previous: MIPS 2020—MIPS Final Score Weighting is Same as in 2019

    Next: Quality: An Overview

    DISCLAIMER AND LIMITATION OF LIABILITY: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.

    COPYRIGHT© 2020, American Academy of Ophthalmology, Inc.® All rights reserved. No part of this publication may be reproduced without written permission from the publisher. American Academy of Ophthalmic Executives® and IRIS® Registry, among other marks, are trademarks of the American Academy of Ophthalmology.®

    All of the American Academy of Ophthalmology (AAO)–developed quality measures are copyrighted by the AAO’s H. Dunbar Hoskins Jr., MD, Center for Quality Eye Care (see terms of use).