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MIPS CY 2019 Proposal

Last month CMS shared their Physician Fee Schedule proposed rule, and they included their MIPS CY 2019 proposals. Here is a summary of the proposals for the MIPS CY 2019 program, specifically focused on areas of interest to health IT developers. The final rule will be likely be released around the October timeframe. While everything is technically in proposal stage, I expect everything listed below to ultimately be finalized in the final rule.

  • Expanded definition of Eligible Clinicians: CMS is expanding the types of clinicians who can participate in MIPS. The clinician types new to MIPS starting in CY 2019 are physical therapists, occupational therapists, clinical social workers, and clinical psychologists. There is some flexibility for these new types of clinicians in terms of allowing them time to adjust to their new status. For example, they can elect to have their Promoting Interoperability (PI) category weighted to 0% if they do not are not able to fully report on those measures. This will give them time to adopt and begin using CEHRT.

  • MIPS Scoring: As before, four categories are used for scoring, and points are weighted from each category and added together to determine MIPS Composite Score. The default weighting that is proposed is 45% for Quality, 15% for Cost, 15% for Improvement Activities, and 25% for Promoting Interoperability (PI). However, there are many ways which the categories can be re-weighted depending on various exclusions (e.g., newly eligible clinician types not able to report on PI category).

  • MIPS Composite Score Performance Threshold: The new MIPS Composite Score (MCS) performance threshold for eligible clinicians to meet for to avoid negative payment adjustment is 30 points for CY 2019 performance period, up from 15 points in CY 2018. CMS shared their current target for 2022 performance period will be a performance threshold between 63-69 points, which is essentially the mean score from the actual CY 2017 performance results, but this is just the current projection and will be adjusted in the future. However, it shows the trend CMS is taking with their MCS. Basically, what was “average” in CY 2017 will be the “minimum” in CY 2022.

  • 2015 Edition CEHRT Only: For CY 2019, only 2015 Edition certified EHR technology can be used for Promoting Interoperability category. CMS is very emphatic about that, and this is a final decision.

  • Unchanged Performance Periods: The reporting period for MIPS CY 2019 will be the same as in CY 2018. Promoting Interoperability and Improvement Activities performance categories for 2019 and 2020 will be 90-continuous days. The reporting period for the Quality and Cost categories will remain a full calendar year. Thus, the absolute last date to get your EHR certified to 2015 Edition is Sept 2019, and that is cutting it extremely close.

  • Streamlining of Measures: The PI measures have been changed:

  • The required measures for Promoting Interoperability category will be reduced to 6 measures: e-Prescribing, Support Electronic Referral Loops by Sending Health Information (i.e., sending C-CDA summary of care record for transition encounters), Support Electronic Referral Loops by Receiving and Incorporating Health Information (i.e., receiving and incorporating C-CDA summary of care record for transition encounters), Provide Patients Electronic Access to Their Health Information (i.e., patient portal or API access), and two public health registry measures.

  • The "Support Electronic Referral Loops by Receiving and Incorporating Health Information" measure is technically a new measure, but it is really just combining the very similar the Request/Accept Summary of Care measure and the Clinical Information Reconciliation measure into one measure.

  • VDT, secure messaging, and patient-generated health information measures will be dropped for MIPS, although it should be noted they will still be part of the CMS Medicaid Promoting Interoperability Program for eligible providers.

  • While not a measure to be scored on, the Security Risk Analysis “measure” is still required to be completed in order to submit a PI score.

  • Changing Public Health Measures...Again: For the 3rd time in the three years of MIPS, we have new rules on Public Health measures. Now, it is 10 possible points for reporting on two of the public health measures. Any two can be used, and there are exclusions for each of them (e.g., eligible clinician not diagnose or directly treat any disease or condition associated with a clinical data registry in their jurisdiction during the performance period). CMS also requests comment about possibly dropping public health measures entirely by CY 2022.

  • Bonus Opioid Related Measures: Two bonus measures are introduced to address the opioid epidemic: Querying PDMP and Verify Opioid Treatment Agreement. They offer bonus points in CY 2019, and then in CY 2020 become “normal” measures. Description of each new measure:

  • Querying PDMP: For at least one Schedule II opioid electronically prescribed using CEHRT during the performance period, the MIPS eligible clinician uses data from CEHRT to conduct a query of a Prescription Drug Monitoring Program (PDMP) for prescription drug history, except where prohibited and in accordance with applicable law.

  • Verify Opioid Treatment Agreement: For at least one unique patient for whom a Schedule II opioid was electronically prescribed by the MIPS eligible clinician using CEHRT during the performance period, if the total duration of the patient’s Schedule II opioid prescriptions is at least 30 cumulative days within a 6-month look-back period, the MIPS eligible clinician seeks to identify the existence of a signed opioid treatment agreement and incorporates it into the patient’s electronic health record using CEHRT.

To meet either of these measures, CEHRT capabilities must be used (e.g., eRx and drug formulary for Querying PDMP and possibly Summary of Care/Care Plan for Verify Opioid Treatment Agreement). However, CMS acknowledged that many CEHRT systems do not have the full capabilities to fully automate these activities. Expect more guidance to come from ONC on how this is to be done by certified systems.

  • PI Points: By streamlining the measures, the point system has also become simplified, although I don’t necessarily think it is easier for providers to score high in the PI category. There will no long be Base Measure scoring and Performance Measure scoring and Bonus scoring. Percentage results for each measure are scored based on assigned weight and then totaled together. Also, they are dropping the Improvement Activities using CEHRT bonus points and bonus points for extra public health measures or use of 2015 Edition CEHRT. For CY 2019, there are some “bonus” points for submitting on the two new e-Prescribing measures Please see the below example from CMS on scoring of Promoting Interoperability category.

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