Participating in MIPS? What you need to know for 2019

Participating in MIPS? What you need to know for 2019

Medicare expanded eligibility for its Quality Payment Programs (QPP) as well as changed a slew of reporting measures that will affect doctors of optometry participating in the 2019 program year.

"The rules have changed in 2019, this is an ever-evolving scenario."

Published in November, the Centers for Medicare & Medicaid Services' (CMS') 2019 Physician Fee Schedule finalized revisions to the Merit-based Incentive Payment System (MIPS) that de-emphasized low-value, low-priority measures in favor of those with greater impact on health outcomes. In turn, many of these changes will impact the way doctors of optometry report CY2019 measures to meet or exceed the MIPS performance threshold score.

"The rules have changed in 2019, this is an ever-evolving scenario," says Jeff Michaels, O.D., AOA Quality Improvement and Registries Committee member. However, the bottom line for MIPS participation remains the same: meet or exceed the threshold performance score, Dr. Michaels explains in AOA's MIPS 2019: Big Changes in the Rules webinar.

Since MIPS' launch in 2017, the performance threshold score has steadily risen from only 3 points to 30 points in 2019. But by 2021, the performance threshold score will be set by the mean or median score of MIPS providers. That's important because the mean score for all 2017 MIPS providers was 74, whereas the small practice category (of which many doctors of optometry will fall) scored only 43 points.

Although most eligible providers (EPs) in the small practice category received a bonus or "exceptional performance" in 2017, the rising bar means EPs will have to do more in the years ahead-and with several measures now worth less in 2019.

Access the AOA's detailed guidebook to the 2019 MIPS changes here.

2019 rules allow opt-in

Significantly, the 2019 Medicare PFS changed the MIPS eligibility threshold by allowing clinicians to opt-in to the quality program. Although CMS still exempts clinicians from MIPS if it's their first year of Medicare Part B participation, if they're participating in an Advanced Alternative Payment Model or if they're below the low-volume threshold, the latter exemption has been redefined for 2019. The low-volume threshold is now defined as:

  • Clinicians who submit ≤ $90,000 in Medicare Part B allowable charges; or
  • Clinicians who see ≤ 200 Medicare patients per year; or
  • Clinicians who perform ≤ 200 covered professional services (ex., 92004, 92133, 92020)

While clinicians meeting all three criteria are required to participate, anyone meeting one exemption may choose not to participate and accept the traditional Medicare PFS. However, CMS permits clinicians to opt-in this year and it can be to doctors' advantage, Dr. Michaels says.

"The great thing about opting in is you can go the entire year calculating to see if you're performing well within MIPS and you don't have to make a decision about opting in until the end of 2019," Dr. Michaels says. "In the first months of 2020, you can add up all your categories and if you did well you can submit data to CMS, opting in and getting the bonus."

Click here to check your QPP participation status.

2019 rules change measures

Additionally, CMS revised the way clinicians' MIPS Final Scores are weighted; 'Quality' was reduced to 45 percent and 'Cost' was increased to 15 percent, while 'Improvement Activities' and the renamed, 'Promoting Interoperability' category, remained 25 percent and 15 percent, respectively. So, too, beyond the threshold performance score, the exceptional performance threshold was set at 75 points for clinicians scoring the maximum bonus. But, where doctors of optometry should pay close attention are CMS' changes to reporting measures in those categories, namely Quality, Promoting Interoperability and Improvement Activities.

Doctors of optometry still must report 6 Quality measures in 2019 with at least one 'outcomes' measure or one 'high priority' measure if doctors cannot report an outcomes measure. Dr. Michaels advises MIPS participants to choose these wisely as they will report on 60 percent of patients across all payers (if using EHR or AOA MORE reporting).

In the past, clinicians could select across a long list of Quality measures, but in recent years CMS has started to cull and 'top out' certain measures. In 2019, CMS completely removed two separate measures related to diabetic retinopathy and age-related macular degeneration (AMD) AREDS counseling (for EHR reporting), and topped out two more related to diabetic eye exams and documentation of meds. The latter two are now capped at 7 points max, whereas a measure related to tobacco cessation was capped at 3 points.

In the same way, claims-based reporters will see similar changes. In addition to those measures topped out for EHR reporting, claims-based also had measures related to primary open-angle glaucoma reduction and AMD examination topped out.

2019 rules emphasize updated EHR

In 2019, CMS emphasized the Promoting Interoperability (PI) category of MIPS will require 2015 Edition EHR (previously known as Stage 3 under meaningful use). Dr. Michaels notes that many doctors are likely still using 2014 editions, but many EHR vendors will upgrade to the new version soon. As such, it's important for doctors to wait until their 2015 EHR upgrade is ready before selecting a 90-day reporting period and performing a Security Risk Assessment.

Also, CMS changed scoring within PI. In addition to removing the base score and performance score, CMS created four new categories:

  • E-Prescribing
  • Worth 10 percent of PI score
  • Providing patient access to an online portal
  • Worth 40 percent of PI score
  • Access to a health information exchange
  • Worth 20 percent for sending information via EHR
  • Worth 20 percent for receiving information via EHR
  • Registry
  • Worth 10 percent for participating in two registries (though clinicians may participate in only one, such as AOA MORE, if a second registry is unavailable)

2019 rules emphasize comprehensive eye exams

In 2017, AOA offered CMS an innovative policy recommendation that would create a MIPS Improvement Activity (IA) to encourage greater patient education efforts about in-person, comprehensive eye exams, and CMS embraced the recommendation.

In 2019, doctors may provide patient literature or facilitate conversations about the value of comprehensive eye examinations using VISION USA or Think About Your Eyes resources to earn this IA credit (IA_AHE_7). Significantly, CMS validated the necessity of comprehensive eye examinations in the rule-writing process with comments that stated "since comprehensive eye exams are relatively low-cost interventions and early detection of conditions that can be identified through an eye exam may reduce more costly treatment later, we believe this improvement activity will not unnecessarily increase expenditures for public programs and the target population."

Dr. Michaels noted additional IAs that doctors may consider for attestation, including:

  • Participation in a QCDR (such as AOA MORE) that promotes use of patient engagement tools
  • Participation in a QCDR (such as AOA MORE) that promotes collaborative learning
  • Participation in a QCDR (such as AOA MORE) for quality improvement

Are you using AOA resources?

Although a lot to digest, Dr. Michaels notes AOA offers step-by-step checklists and webinars that can explain what participating doctors must accomplish to avoid a penalty, especially AOA's 2019 MIPS Guidebook-Road Map to Success for Doctors of Optometry and AOA's 2019 MIPS Quality Measures for Optometrists. Even more information is available here.

So, too, participating doctors will find advantages using the AOA-member-benefit registry, AOA MORE.

Click here for more information about AOA MORE, including FAQs and additional AOA resources.

February 20, 2019

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