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  • MIPS Final Score, Penalties, Bonuses—What’s New for 2019

    By Chris McDonagh and Jessica Peterson, MD, MPH

    Excerpted from “MIPS—What’s New for 2019”, a two-part EyeNet series (January and February, 2019), published online ahead of print. You also should bookmark EyeNet's MIPS 2019 (also published online ahead of print) and the Academy's MIPS hub page.

    MIPS final score—quality’s contribution is down, cost’s is up. In 2021, your payments for Medicare Part B services will be adjusted up or down based on your 2019 MIPS final score, which is a composite score that can range from 0 to 100 points and is based on your scores in 4 performance categories:

    • Quality is weighted at 45% (down from 50% in 2018), meaning it can contribute up to 45 points to your 2019 MIPS final score.
    • Promoting interoperability (PI) is weighted at 25% (same as 2018).
    • Improvement activities is weighted at 15% (same as 2018).
    • Cost is weighted at 15% (up from 10% in 2018). CMS states that it expects to continue boosting cost’s weight by 5%, and reducing quality’s weight by 5%, every year until they are each weighted at 30% of the final score. (Cost is required by statute to be weighted at 30% of the final score by performance year 2022.)

    Your scores can be reweighted. Like in 2018, the relative weights of these four scores can be adjusted. For example, if you qualify for a PI exception, PI’s weight in your 2019 MIPS final score will be re­duced to zero, and quality’s weight will be increased to 70%.

    Final score bonus points— one bonus has been retained, the other moved to quality. As in 2018, a complex patient bonus (0-5 points) can boost your MIPS final score. However, the small practice bonus has been moved from the MIPS final score to the quality performance category score.

    Table: Bonuses and Penalties

    2019 MIPS Final Score 2021 Payment Adjustment
    0-7.5 points – 7% penalty
    7.51-29.99 points Less than – 7% penalty*
    30 points Neutral (no bonus; no penalty)
    30.01-74.99 points Small bonus*
    75-100 points Small bonus* + exceptional performance bonus*
    * The penalty and these two bonuses will be based on linear sliding scales. For each of the bonuses, for example, the higher your 2019 score, the greater the positive adjustment that will be applied to your 2021 payments.

    Negative payment adjustments may be higher. As shown in Table 16: Payment Penalty, if your 2019 MIPS final score is less than 30 points, your payments for Medicare Part B services in 2021 will incur a negative payment adjustment; if you score 7.5 points or less, those payments will be subject to the maximum 2021 penalty of – 7%. (By comparison, during the 2018 performance year, scores of less than 15 points result in a negative payment adjustment in 2020, with scores of 0-3.75 points resulting in the maximum 2020 penalty of – 5%). 

    How the positive payment adjustments are funded. The performance bonus for clinicians who exceed 30 points is funded by the reduction in payments to those who score fewer than 30 points. The exceptional performance bonus for scoring at least 75 points is funded by a separate $500 million bonus pool.

    No change in performance periods. For 2019, the PI and improvement activities performance categories each require a performance period of at least 90 consecutive days; the performance period for quality and cost is the full calendar year. CMS also plans to maintain the same performance periods in the 2020 performance year.

    Avoiding the payment penalty is harder now that you must score at least 30 points—you must do more than report improvement activities. Scoring 100% for improvement activities contributes 15 points to your MIPS final score. For the 2018 performance year, that would have been enough to avoid the 2020 MIPS payment penalty. But if you max out your improvement activities score in 2019, you will still have to score points for quality measures and/or PI measures in order to get the 30 points that are needed to avoid a 2021 penalty.

    Special scoring for clinicians who join a practice late in the year. If you join a practice in the last three months of 2019, CMS will assume that you won’t have enough measures available to you to participate as an individual in MIPS. What does this mean for your score? If you join a newly formed practice (established after Oct. 1, 2019) or if you join an established practice where the clinicians are reporting as individuals, CMS will award you a MIPS final score of 30 points, which means you would get a neutral payment adjustment in 2021 (no bonus and no penalty). If you join an established practice that is reporting as a group, you would get the practice’s group score.

    Next: MIPS Eligibility Criteria—What’s New for 2019

    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.

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