What You Need to Know About MIPS Changes in 2020
Some Key 2020 MIPS Updates
In November 2019, CMS published the 2020 Quality Payment Program Final Rule (the “2020 MIPS Final Rule”). Below is a summary of some of the most notable changes to the Merit-Based Incentive Payment Program (MIPS). For a complete list of changes, please review the 2020 MIPS Final Rule or CMS’ Quality Payment Program Resource Library.
1. MIPS Performance Category Weight
CMS maintained the current weight of the four categories without making changes:
- Quality = 45%
- Cost = 15%
- Improvement Activities = 15%
- Promoting Interoperability = 25%
2. Performance Threshold
For the 2020 performance period:
- CMS increased the performance threshold to 45 points.
- CMS increased the exceptional performance threshold, which is now set at 85 points.
- Positive payment adjustment could be up to +9% and the maximum negative payment adjustment is up to -9% (adjustment made to 2022 reimbursement).
For the 2021 performance period:
- The performance threshold will be set at 60 points.
- Exceptional performance will remain at 85 points.
3. The Quality Category Data Completeness Requirement and Flat Percentage Benchmarks
CMS increased the data completeness requirement to 70% in the 2020 MIPS performance year. Measures that don’t meet data completeness will earn 0 points (small practices will continue to earn 3 points).
In addition, CMS established a special benchmarking policy “flat percentage benchmarks” in limited cases where CMS determines that a measure’s otherwise applicable benchmark could potentially incentivize treatment that could be inappropriate for particular patients.
This would apply for the following measures:
- MIPS #1 (NQF 0059): Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%).
- MIPS #236 (NQF 0018): Controlling High Blood Pressure
“In flat percentage benchmarks, any performance rate at or above 90% would be in the top decile, any performance rate between 80% and 89.99% would be in the second-highest decile, and so on.” (See 2020 Quality Payment Program Final Rule Overview Fact Sheet, pp. 10-11 “Modified Benchmarks to Avoid Potential Patient Risk”)
4. New and Removed Quality Benchmarks
CMS added seven new specialty sets for Speech-Language Pathology, Audiology, Clinical Social Work, Chiropractic Medicine, Pulmonology, Nutrition/Dietician and Endocrinology. Note: Clinical Social Workers are not a MIPS eligible clinician type at this time. (See MIPS 2020 Quality Performance Category Quick Start Guide, p.8).
CMS finalized the removal of 42 quality measures in the 2020 Performance Period. Highlighted measures noted below were available for reporting through EMA® EHR in the 2019 Performance Period.
If you have picked any of the above-listed measures during the 2019 Performance Period, we recommend selecting replacement measure(s) for the 2020 MIPS Reporting Period.
CMS also added three measures in the 2020 Performance Period.
It’s important to mention that CMS recognizes the importance of providing clinicians with feedback regarding their MIPS performance. For that reason, CMS requires Qualified Registries to provide performance feedback at least four times a year. Additionally, CMS will require Qualified Data Registries to be able to submit data for all MIPS performance categories that require data submission to reduce the reporting burden.
5. Improvement Activities (IA) Category
- CMS added 2, modified 7 and removed 15 Improvement Activities.
- CMS will not continue the study on factors associated with quality reporting in the 2020 performance year.
- CMS is changing the group reporting to require at least 50% of the clinicians in the group to attest to performing the same Improvement Activity for any 90 day period within the performance year.
6. Promoting Interoperability (PI) Category
- Starting with the 2019 performance year and continuing in the 2020 performance period, the optional Query of PDMP measure required a yes/no response instead of a numerator/denominator.
- CMS will redistribute the points for the “Support Electronic Referral Loops by Sending Health Information measure” to “Provide Patients Electronic Access to Their Health Information measure” if an exclusion is claimed.
- Starting in 2020, the optional “Query of PDMP” measure will require a yes/no response instead of a numerator/denominator.
- Additionally, in 2020, groups and virtual groups qualify for automatic reweighting of this category when more than 75% of the clinicians in the group or virtual group are hospital-based.
7. The Cost Category
- CMS revised the name specifications for the “Medicare Spending Per Beneficiary Measure” to MSPB-C or MSPB Clinician.
- CMS added 10 new episode-based measures.
- Measure attribution will be different for individuals and groups and will be defined in the applicable measure specifications.
- TPCC attribution will require a combination of (i) an E&M service and (ii) general primary care service or a second E&M service, from the same clinician group.
- TPCC attribution will exclude certain clinicians who primarily deliver certain non-primary care services (e.g., general surgery) or are in specialties that are unlikely to be responsible for primary care services (e.g., dermatology).
- MSPB Clinician attribution will have a different methodology for surgical and medical episodes.
Now that we’ve highlighted the main changes to now for MIPS 2020. Let’s take a look at how Modernizing Medicine® can help.
Why and How to Keep Up With MIPS Changes?
Keeping up with the seemingly endless changes around the Merit-Based Incentive Payment System (MIPS) is no easy feat. It can feel like a full-time job deciphering what the changes are, how to adjust and make sure you’re on track for success. And reading almost 3,000 pages of government rules and regulations can make anyone’s head spin. The good news is, you don’t need to take MIPS on all on your own or put the onus on your staff to keep you updated.
We get it. The more administrative tasks you have to factor into your week, the more burnout you may feel and the less time you have to focus on your patients.
Working with a company like Modernizing Medicine, you’ll get both the technology and team with our MIPS Advisory Services that offers you access to our concierge-style program. It provides our EMA EHR clients access to our CMHP-MIPS specialists to help put them on the path for MIPS success.
If you’re wondering just how our clients have done, the results speak for themselves. 99.9 percent of our MIPS Advising clients met their 2017 score goals and 100 percent met their 2018 score goals*. Pretty remarkable.
Here are just a few of the many successes our clients have shared with us:
“Not only did we meet the minimum MIPS guidelines, but all of our providers will receive incentives.” – Sunny Holman, Practice Manager, Windsor Dermatology
“Submitting for MIPS was a breeze because the system and Modernizing Medicine’s Advisory Services helped walk us through the process.” – Carren Whitt, MBA, Practice Administrator, Ear, Nose and Throat Associates of East Texas
“The automated MIPS tracking tools that are built into EMA captures the required data for CMS reporting without difficulty, and I’m even able to view my estimated score in real time.” – Randy Burks, MD, FACS, Ophthalmology Consultants
So why choose Modernizing Medicine for more than your EHR of choice? It comes down to a few crucial components:
- Our Certified MIPS Healthcare Professionals: Spare yourself from reading almost 3,000 pages of jargon to keep up with the changes and let our team help decode what you need to know. This frees up you and your staff to focus on what matters most, your patients. They will work with you hand in hand to help come up with a plan and answer questions throughout the process.
- Experienced in Specialty-Specific, Value-Based Care: No two medical specialties are alike. It’s a principle that our company was founded on with our specialty-focused EHR platform. Our MIPS Advisors can help pinpoint the measures that are most relevant to you and your specialty practice.
- Experience Using our EHR, EMA: Consultants are great, but they don’t know our EHR system, EMA, like our on-staff MIPS Advisors do. Skip the generic advice and work with a professional who can guide you through how to track and manage each MIPS measure in EMA. Plus, benefit from their knowledge of when a new MIPS feature or shortcut is rolled out in the product.
- Hands-On: It’s all about that personal touch and relationship building. Your MIPS Advisor will know your practice, EMA and MIPS. It’s a trifecta! Instead of guessing about your performance, our advisors can notify you if something is off base and how to adjust workflow before it’s too late to change.
Still on the fence? Here are nine questions you should ask a vendor when it comes to MIPS and how Modernizing Medicine could be the right fit for your practice:
1) Is your company’s EHR system certified according to the 2015 guidelines so my practice can participate in value-based care?
Modernizing Medicine’s award-winning EHR system**, EMA, is a 2015 Edition Certified Electronic Health Record Technology (CEHRT) and our clients can participate in MIPS. You can easily collect your MIPS data within EMA and view a real-time scorecard in our EHR that shows your estimated progress on each measure.
2) Which Promoting Interoperability requirements will be featured in your company’s EHR?
Modernizing Medicine has a MIPS dashboard that includes all of this year’s Promoting Interoperability measures and keeps you updated on your estimated progress/points for each measure. We even have our own built-in, specialty-specific Specialized Registries which can be used for the Clinical Data Registry Reporting measures that are worth 10 points.
3) How is your company going to help me be successful in MIPS?
As an industry leader in specialty-specific content and usability, we offer built-in MIPS composite score reporting, robust analytics and benchmarking reports that document your estimated performance in near real time. We also offer patient engagement tools such as reminders, patient kiosk and patient portal, along with concierge coaching and MIPS advisory services.
4) Which Improvement Activities (IA) and Promoting Interoperability (PI) options will be included/built into your company’s EHR?
EMA supports a large number of MIPS measures, all of which can be viewed in the MIPS dashboard.
Here are some of the IA options we suggest documenting in EMA:
- 24/7 access to MIPS-eligible clinicians
- Intensive care management
- Medication management
- Closing the referral loop
- Timely communication of test results
- Patient handouts in an appropriate language
- Health Information Exchange (HIE)
- Prescription Drug Monitoring Program (PDMP) that can be queried right from EMA✝
- An enhanced patient portal that provides up-to-date information related to relevant chronic disease health or blood pressure control
EMA also features the following PI measures, and the full list of available measures can be viewed in the MIPS dashboard or provided upon request:
- Optional Prescription Drug Monitoring Program Bonus measure
- Provide Patient Access to Their Health Information
- Support Electronic Referral Loops by Sending Health Information
- Support Electronic Referral Loops by Receiving and Incorporating Health Information
- Clinical Data Registry Reporting
5) Can your EHR submit the MIPS quality data for me as a qualified registry, or do you (or I) outsource this to a third party?
Our clients can submit their MIPS data directly to CMS through the Modernizing Medicine Qualified Registry✝ .
6) Is the data that I need to report MIPS automatically captured in your company’s EHR at the point of care, or do you (or I) need to export this type of data outside of your EHR?
EMA automatically captures all the data you need at the point of care to build and report your composite MIPS score. A built-in, easy-to-read scorecard to show you your estimated performance in MIPS is included*.
7) Does your EHR have built-in, real-time analytics reports for all MIPS categories (Quality, Cost, Promoting Interoperability and Improvement Activities) so I can see how I am performing?
Our solutions automate the composite score elements that are used to calculate and monitor your estimated MIPS score, with the exception of cost, which is calculated by CMS. Access to the built-in dashboard that lets you track your estimated Quality, PI and IA scores is included with your EMA EHR subscription.
8) Will your company have everything I need to be successful with MIPS, or do I need to outsource any functions or reporting to a third party?
Unlike other companies that require you to use multiple vendors and input information manually, Modernizing Medicine offers virtually everything you need to help you to succeed with MIPS without outsourcing to a third party.
9) Is your company offering any type of consulting or advisory services to help me be successful in MIPS?
We offer a concierge level style of MIPS Advising to help you avoid a negative MIPS payment adjustment and work towards earning the exceptional performer bonus. The MIPS Advisory team is comprised of Certified MIPS Health Professionals (CMHP) who have a clinical background with a strong knowledge of using EMA in clinical and administrative settings.
The short version of all of this? Don’t let MIPS be a four-letter word that gets in the way of doing what you do best – treating your patients. It’s okay to ask for help and that’s where Modernizing Medicine’s Advisory Service can help deliver.
1. 2020 Quality Payment Program Final Rule. https://www.federalregister.gov/documents/2019/11/15/2019-24086/medicare-program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other
2. Centers for Medicare and Medicaid (CMS). 2020 Quality Payment Program Final Rule Overview Fact Sheet. https://qpp-cm-prod-content.s3.amazonaws.com/uploads/737/2020%20QPP%20Final%20Rule%20Fact%20Sheet.pdf
3. Centers for Medicare and Medicaid (CMS). 2020 Quality Performance Category Quick Start Guide. https://qpp-cm-prod-content.s3.amazonaws.com/uploads/823/2020%20Quality%20Quick%20Start%20Guide.pdf
4. Centers for Medicare and Medicaid (CMS). Calendar Year (CY) 2020 Physician Fee Schedule (PFS) Final Rule: Finalized (New and Updated) Qualified Clinical Data Registry (QCDR) and Qualified Registry Policies. https://qpp-cm-prod-content.s3.amazonaws.com/uploads/805/QCDR%20and%20Qualified%20Registry%20Updates%202020%20Final%20Rule%20Factsheet.pdf
*2019 Black Book™
**Scores are estimated based on the MIPS scoring criteria published by the Centers for Medicare and Medicaid Services (CMS).
✝ Additional fees may apply; may not be available for all states and users.
 Information relating to our EHR certification, including certain costs and limitations, can be found at modmed.com/costs-and-limitations
Hayder Hussein, MPH, CPHQ, CMHP
ASSOCIATE PRODUCT MANAGER
Hayder Hussein joined Modernizing Medicine in November 2017 as an associate product manager where he focuses on EHR regulatory compliance and population health management. He’s a current healthcare quality and patient safety professional and a former physician. Hayder holds a master’s degree in public health from DePaul University in Chicago, IL.
Jayne Engelking (Collard), CMHP
SENIOR PROGRAM MANAGER
Jayne Engelking (Collard) is the Manager of Advisory Services and a Certified MIPS Health Professional (CMHP). Prior to her 7+ years at Modernizing Medicine, Jayne was a MA at a wonderful family owned Dermatology practice in Durango, CO. Jayne has a partial masters in Mental Health Counseling and currently leads an EMAzing team of MIPS Advisors for both EMA and gGastro while living and working out of Colorado. Jayne and her hubby enjoy traveling and spending time with their fur babies in the mountains.