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.
Below are the most significant changes to MIPS quality reporting.
Getting a high score for quality becomes more challenging each year. The bottom line is that if you report the same quality measures as last year, and get the same performance rates, your quality score may be lower, which would be detrimental to your MIPS final score. (Remember, your 2019 MIPS final score determines the size of your 2021 payment adjustment; the maximum bonus is likely to be modest, but the maximum penalty will be –7%.) Review the quality measures that are availabe for reporting via IRIS Registry-EHR integration, for manual reporting via the IRIS Registry, and for claims-based reporting, and watch for measures that have scoring limitations.
Claims-based reporting: Expanded access for small practices; not an option for large practices. In 2019, clinicians in large practices can no longer report quality measures via Medicare Part B claims. However, clinicians in small practices can continue to do so and—new for 2019—can do so even when reporting as a group, not just when reporting as individuals. Warning: Many claims-based quality measures are topped out at a low decile, which hinders your ability to get a high score for quality with claims-based reporting.
Facility-based scoring available for certain clinicians. Facility-based scoring will only be available to you if you provide at least 75% of your covered professional services at an inpatient hospital (place of service [POS] code: 21), on-campus outpatient hospital (POS code: 22), or emergency room (POS code: 23), with at least one service at an inpatient hospital or emergency room. This will be based on claims submitted between Oct. 1, 2017, and Sept. 30, 2018. CMS will only assign you the facility's quality score if it is higher than your individual quality score. This is unlikely to be an option for many ophthalmologists.
Bonus points for opioid-related measures. In response to the opioid epidemic, CMS now considers opioid-related quality measures to be high priority and, thus, eligible for the high-priority bonus.
Bonus for electronic reporting now requires 2015-edition CEHRT. Like last year, you can earn bonus points if you report quality measures using a certified EHR technology (CEHRT) for end-to-end reporting, but in 2019 you will only get this bonus if you are using the 2015-edition CEHRT.
Some topped out measures may be retired early. CMS considers a measure to be topped out when a lot of clinicians are attaining, or almost attaining, maximum performance for that measure (e.g., the average performance rate is 95% or higher). CMS had previously established a four-year life cycle for such measures—if they are topped out for at least two years, they would be subject to a seven-point cap; topped out for three consecutive performance years, they would be eliminated in the fourth year. Now CMS is accelerating that process in some cases: If a measure is extremely topped out (e.g., the average performance rate is 98% or higher), it can be removed from MIPS the following year, even if it hasn’t been topped out for three consecutive years. (Note: Topped out QCDR measures also are on an accelerated timetable for removal from MIPS, even if they aren’t extremely topped out.)
In rare cases, a measure might be “suppressed.” During the course of 2019, changes in clinical guidelines may mean that continued adherence to a measure could result in patient harm and/or provide misleading results as to good quality care. In the unlikely event that this happens with one of ophthalmology’s measures, CMS could suppress that measure. This means that if you submitted data on the measure before it was suppressed—because, for example, you were reporting it by claims—1) you wouldn’t score points for that measure and 2) when CMS calculates your quality score it would reduce your denominator by 10 points (so you wouldn’t be penalized for reporting the suppressed measure).
Small practice bonus is moved to quality. For 2019, CMS will no longer apply a 5-point small practice bonus to the MIPS final score; instead, when calculating your quality score, it will apply a 6-point bonus to your numerator for that performance category—but only if you report data on at least one quality measure. (Note: Your quality score is capped at 100%. Neither the small practice bonus nor the other quailty performance category bonuses can increase your quality score above 100%.)
New QCDR measures available via the IRIS Registry. As a QCDR, the IRIS Registry can develop subspecialty-specific measures for MIPS reporting. The Academy, working with subspecialty societies, has developed several new QCDR quality measures:
IRIS Registry adds three MIPS CQMs for manual reporting. In addition to the new QCDR measures, you have three additional MIPS clinical quality measures (MIPS CQMs) to report manually via the IRIS Registry:
CMS renumbered some QCDR measures. Some QCDR measures underwent changes to their specifications and were renumbered.
CMS removed some MIPS CQMs. The eliminated measures include three MIPS CQMs that had been useful for Academy subspecialists:
- Measure 18: Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy
- Measure 140: AMD: Counselling on Antioxidant Supplement
- Measure 224: Melanoma: Avoidance of Overutilization of Imaging Studies
Some QCDR measures removed. These 2018 QCDR measures will not be available in 2019:
- IRIS9: Diabetic Retinopathy: Documentation of the Presence or Absence of Macular Edema and the Level of Severity of Retinopathy
- IRIS11: Nonexudative AMD: Loss of Visual Acuity
- IRIS17: Acute Anterior Uveitis: Post-Treatment Grade 0 Anterior Chamber Cells
- IRIS20: Idiopathic Intracranial Hypertension: No Worsening or Improvement of Mean Deviation
- IRIS25: Adenoviral Conjunctivitis: Avoidance of Antibiotics
- IRIS26: Avoidance or Routine Antibiotic Use in Patients Before or After Intravitreal Injections
- IRIS31: Avoidance of Genetic Testing for AMD
- IRIS34: AMD: Disease Progression
If you are reporting via IRIS Registry–EHR integration, 3 measures are subject to the 7-point cap in 2019. You won't be able to earn more than 7 achievement points for these measures:
If you are reporting manually via the IRIS Registry –EHR integration, 10 measures are subject to the 7-point cap in 2019. You won't be able to earn more than 7 achievement points for these measures:
What if you use multiple collection types? Suppose, for example, you report six measures by Medicare Part B claims and you also report the same six measures manually via the IRIS Registry portal. If you did that during the 2018 performance year, CMS would 1) assess your score for the six claims-based submissions, 2) assess your score for the six IRIS Registry–based submissions, and 3) assign you the highest of those two scores (i.e., your score would either be based on the six measures reported by claims or the six measures reported via the IRIS Registry portal). During the 2019 performance year, CMS will make that comparison for individual measures—so your final quality score could, for example, be based on five measures that were reported via the IRIS Registry and one measure reported via claims.
Previous: MIPS Promoting Interoperability—Meet These Nine Requirements in 2019
Next: MIPS Improvement Activities—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.
COPYRIGHT© 2019, 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®.