1. MIPS Year 3 Performance Year 2019 Final Rule

2. Who is Eligible? Expanded Participation NEW for Year 3 Year 1, 2, & 3
Physical Therapist
Occupational Therapist
Speech-Language Pathologist
Audiologist
Clinical Psychologist
Registered Dietitian or Nutrition Professionals
Year 1, 2, & 3
Physicians
Physician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered Nurse Anesthetists
>$90,000 in Part B allowed charges for covered professional services
Provide care to >200 Medicare beneficiaries
Provide >200 covered professional services under the PFS

3. Low Volume Threshold 1st year of Medicare participation
Participants in eligible APMs who qualify for the bonus payment
Clinicians or Groups meeting all three LVT criteria – automatically exempt
Low Volume Threshold
$90K in Part B allowed charges for covered professional services
Provide care to Part B-enrolled beneficiaries
Provide covered professional services under the PFS

4. OPT-IN Option
Clinicians/Groups can opt-in, if they meet one or two of the LVT criteria
Opt-in: ECs & groups will be subject to MIPS payment adjustments
Voluntarily Report: ECs & groups will NOT be subject to MIPS payment adjustments but will receive a feedback report on their performance

5. Determination Period Now aligns with the Fiscal Year
MIPS determination period will be used to evaluate clinicians/groups for:
Low-volume threshold
Non-patient facing status
Hospital-based and ASC-based statuses
MIPS determination period includes two 12-month segments
1st – October 1, 2017 – September 30, 2018 (Includes a 30-day claims run out)
2nd – October 1, 2018 – September 30, 2019 (Does not include a 30-day claims run out)

6. Reporting Options
Same as Year 1 & 2 INDIVIDUAL NPI AND TIN where they reassign benefits GROUP 2 or more clinicians NPIs who have reassigned their billing rights to a single TIN
Groups will be assessed as a group across all 4 MIPS performance categories.

7. New MIPS Terms Data Submission– What, Who and How
Collection Type is a set of quality measures with comparable specifications and data completeness criteria including, as applicable: electronic clinical quality measures (eCQMs); MIPS clinical quality measures (CQMs) (formerly referred to as “Registry measures”); Qualified Clinical Data Registry (QCDR) measures; Medicare Part B claims measures; CMS Web Interface measures; the CAHPS for MIPS survey measure; and administrative claims measures.
Submitter Type is the MIPS eligible clinician, group, or third party intermediary acting on behalf of a MIPS eligible clinician or group, as applicable, that submits data on measures and activities.
Submission Type is the mechanism by which the submitter type submits data to CMS, including, as applicable: direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web Interface.
*There is no submission type for cost data because the data is collected and calculated by CMS from administrative claims data submitted for payment
*DEADLINE for submitting all data is March 31, 2020

8. Category Weights Performance Period QUALITY COST IA PI
100 Possible Points
Final Score
45%
15%
15%
25%
Performance Period
Same as Year 2
QUALITY
COST IA
12 Months
12 Months
90 Days
90 Days
Minimum Performance Period for each Category

9. Performance Threshold & Payment Adjustment
YEAR 3 (2019)
Performance Threshold – 30 Points
Exceptional Performance Threshold – 75 points
Payment Adjustment at +/- 7% for payment year 2021
YEAR 2 (2018)
Performance Threshold – 15 Points
Exceptional Performance Threshold – 70 points
Payment Adjustment at +/- 5% for payment year 2020

10. Complex Patient Bonus 5 Points added to Final Score
Calculation of the average Hierarchical Condition Category (HCC) risk score and the proportion of full benefit or partial benefit dual eligible beneficiaries.
Determination Period – The second 12 month segment
(Oct. 1, 2018 – Sept. 30, 2019)

11. 2019 PERFORMANCE CATEGORIES

12. QUALITY REQUIREMENTS: (Same as Year 2)
Report on at least 6 Quality Measures
One of the 6 MUST be an Outcome or High Priority Measure
Outcome Measures include: Intermediate-Outcome & Patient Reported measures
High Priority Measures include Opioid-related measures.
Performance period is for 12 months

13. QUALITY Eligible Clinicians Reporting as Individuals
Submission Type: Direct; Log-in & Upload; *Medicare Part B Claims
Collection Type: eCQMs; MIPS CQMs; QCDR measures; *Medicare Part B Claims measures
Eligible Clinicians Reporting as Group
Submission Type: Direct; Log-in & Upload; CMS Web Interface (group of 25 or more ECs); *Medicare Part B Claims
Collection Type: eCQMs; MIPS CQMs; QCDR measures; CMS Web Interface measures; *Medicare Part B Claims measures; CMS approved survey vendor measure; Administrative claims measures
*Medicare Part B Claims is for the small practice ONLY (15 or fewer ECs) –NEW for YEAR 3
(“Medicare Part B Claims” differs from “administrative claims” in the they require MIPS ECs to append certain billing codes to denominator-eligible claims to indicate the required quality action or exclusion occurred)
Individuals/Groups can use multiple collection types. – NEW for YEAR 3
If the same measure is submitted via multiple collection types, the one with the greatest number points will be selected for scoring.

14. QUALITY Scoring: 45% of the MIPS final score
Each measure will be scored on a scale from 1-10 or 1-7 for Topped Out measures when the
following criteria is meet: Data Completeness; Case Volume; and the measure has a benchmark.
Data Completeness = 60%
Failure to meet data completeness on a quality measure:
Large Practice receives 1 point for the measure
Small Practice receives 3 points for the measure
Case Volume = 20 Cases
Failure to meet case volume, the practice of any size would yearn 3 points for the measure.
Benchmark
If there is NO benchmark for the quality measure but data completeness and/or case volume is meet: Practice of any size will receive 3 points for the measure.
Improvement Score
Improvement will be measured at the performance category level
Up to 10 percentage points available in the Quality performance category

15. QUALITY
Bonus Points
Report on additional Outcome or High Priority measures beyond the required 1
Outcome measure = 2 points
High Priority measure = 1 point
Quality measures submitted thru EHR end-to-end reporting
1 point for each measure submitted
Small Practice Bonus (15 ECs or less)
6 bonus points will be added to the numerator of the quality category if the EC or group submits data on at least one quality measure
(Year 2 the small practice bonus will be applied to your MIPS final score)

16. QUALITY Inventory Changes Specialty Measure Sets
22 Sets have been modified
4 New Sets: Geriatrics; Physical/Occupational Therapy; Skilled Nursing; and Urgent Care
10 New Quality Measures
23 Quality Measures with Substantive Change
26 Removed Measures

17. PI (Promoting Interoperability
Requirements
Must use EHR technology certified to the 2015 Edition certification criteria.
Your performance on all measures must be a minimum of a 90 consecutive days
Must perform a Security Risk Analysis within the performance period calendar year.
Failure to attest “Yes” to performing a Security Risk Analysis will result in 0 points
Report on all the required measures across all 4 objectives
Failure to report or claim exclusion (if applicable) on any measure will result in 0 points

18. PI (Promoting Interoperability)
Exceptions
CMS will reweight the PI category to 0 and reallocate the 25% to the Quality performance category for the following reasons:
Automatic reweighting:
Hospital-based, Non-Patient Facing, NP, PA, Clinical Nurse Specialist, Certified Registered Nurse Anesthetists, ASC- based, PT, OT, Speech-Language Pathologist, Audiologist, Clinical Psychologist, and Dietitian/Nutrition Professional
Reweighting through an approved application: Deadline December 31st
Insufficient Internet Connectivity
Extreme/Uncontrollable Circumstances
Lack of Control over CEHRT
Hardship exception for clinicians in small practices (15 or fewer)
Decertification exception for clinicians whose EHR was decertified

19. PI (Promoting Interoperability
Objectives/Measures & Points (**Exclusion available)
OBJECTIVE MEASURE POINTS
e-Prescribing e-Prescribing** points
Query of Prescription Drug Monitoring Program (PDMP) Bonus Points
Verify Opioid Treatment Agreement Bonus Points
Health Information Support Electronic Referral Loops by Sending Health Information** 20 points
Exchange Support Electronic Referral Loops by Receiving and
Incorporating Health Information** points
Provider to Patient Provide Patient Electronic Access to Their Health Information points
Exchange
Public Health and Immunization Registry Reporting (Bi-Directional)**
Clinical Data Exchange Electronic Case Reporting**
(Report to 2 Public Health Registry Reporting** points
different agencies Clinical Data Registry Reporting**
or registries) Syndromic Surveillance Reporting**

20. PI (Promoting Interoperability
Exclusions & Redistribution of Points
If a MIPS EC meets the criteria to claim a measure exclusion, the points for that measure will be redistributed to a specified measure. This will maintain the 100 possible points for the PI category.
e-Prescribing (10 points)
5 points added to Support Electronic Referral Loops by Sending Health Information
5 points added to Support Electronic Referral Loops by Receiving & Incorporating Health Information
Support Electronic Referral Loops by Sending Health Information (20 points)
Redistribution of points TBD by CMS at a later date.
Support Electronic Referral Loops by Receiving & Incorporating Health Information (20 points)
20 points added to Support Electronic Referral Loops by Sending Health Information
Note: If exclusions on both measures under the Health Information Exchange objective can be claimed, redistribution of the 40 points will be decided by CMS at a later date.
Public Health & Clinical Data Exchange (claiming 2 measure exclusions) (10 points)
10 points added to Provided Patient Electronic Access to Their Health Information

21. PI (Promoting Interoperability
Scoring
The Security Risk Analysis will yield 0 points towards the PI final score.
The numerator and denominator for each measure will be translated to a performance rate for that measure and would be applied to the total possible points for that measure.
For example, the e-Prescribing is worth up to 10 points. A numerator of 200 and denominator of 250 would yield a performance rate of (200/250) = 80 percent. This 80 percent would be applied to the 10 total points available to determine the measure score.
80% (Performance Rate) x 10 (Possible Points) = 8 points (Measure Score)
The measures under the Public Health and Clinical Data Exchange objective are reported using “yes or no” responses. Eligible clinician would receive the full 10 points for reporting two “yes” responses, or for submitting a “yes” for one measure and claiming an exclusion for another.

22. PI (Promoting Interoperability
Bonus Points
5 Bonus Points – Query of Prescription Drug Monitoring Program (PDMP)
5 Bonus Points – Verify Opioid Treatment Agreement
NOTE: They have removed the bonus points for the PI category for completing certain IA activities. NEW for Year 3
Final Score
To calculate the Promoting Interoperability performance category final score, the measure scores are added together, and the total sum is divided by the total possible points (100). The total sum cannot exceed the total possible points of 100.

23. PI (Promoting Interoperability
Submission Types
Eligible Clinicians Reporting as Individuals or Group:
Direct, Log-in & Upload, and Log-in & Attest

24. IA (Improvement Activities)
Requirements (Same as Year 2)
Select activities that will yield a total of 40 points to receive full credit
Performance period is a minimum of 90 consecutive days

25. IA (Improvement Activities)
Scoring
15% of Final Score
Small Practice/Rural Clinics/HPSA/Non-Patient Facing Clinicians
Medium Weighted Activities = 20 points
High Weighted Activities = 40 points
Large Group Practice
Medium Weighted Activities = 10 points
High Weighted Activities = 20 points
Patient Center Medical Home (PCMH)
EC or group must attest to their PCMH status to receive full credit
Alternative Payment Models (APM)
EC or group must attest to their APM status to receive ½ credit, but can report additional activities to earn the maximum of 40 points.
NOTE: Activities using CEHRT will no longer receive bonus points towards the PI Category – New for Year 3

26. IA (Improvement Activities)
Inventory Changes
6 New Activities
5 Modified Activities
1 Removed Activity
IA PM9 – Participation in Population Health Research
Submission Type
Eligible Clinicians Reporting as Individuals or Group:
Direct, Log-in & Upload, and Log-in & Attest
Attest “YES” for the activities that were carried out during the performance period
For group reporting, only one MIPS eligible clinician in a TIN must perform the improvement activity for the TIN to receive credit

27. COST
Requirements
There is no unique requirements on behalf of the EC or group
There is no submission type, since CMS will automatically collect data through administrated claims
Data will be collected for the full calendar year

28. COST Cost Measures/(Case Minimum)
Medicare Spending per Beneficiary (MSPB)/(35)
Plurality of Part B services billed during the index admission
Total per Capita Cost (TPCC)/(20)
Plurality of primary care services rendered
8 Episode-based measures (5 Procedural Episodes & 3 Acute Inpatient Medical Conditions)
Episode-base measures differs from TPCC & MSPB because they only include items and services related to clinical condition or procedure as opposed to including all services that are provided over a given timeframe.
Elective Outpatient Percutaneous Coronary Intervention (PCI)/(10)
Knee Arthroplasty/(10)
Revascularization for Lower Extremity Chronic Critical Limb Ischemia/(10)
Routine Cataract Removal with Intraocular Lens/(10)
Screening/Surveillance Colonoscopy/(10)
Intracranial Hemorrhage or Cerebral infarction/(20)
Simple Pneumonia with Hospitalization/(20)
ST-Elevation Myocardial Infarction (STEMI) with Percutaneous Coronary Intervention (PCI)/(20)

29. COST Scoring 15% of the ECs Final Score
Each individual MIPS eligible clinician’s and group’s cost performance will be calculated using administrative claims data if they meet the case minimum of attributed patients.
Performance is compared against performance of other MIPS eligible clinicians and groups during the performance period so benchmark is not based on a previous year.
Performance category score is the average of all measures.
If only one measure can be scored, it will serve as the performance category score.

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