Covid-19 Extension and New Policy
The deadline for 2019 MIPS data submission has been extended from March 31, 2020 to April 30, 2020.
MIPS eligible clinicians who have not submitted any 2019 MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year.
CMS is currently evaluating options for providing relief around participation and data submission for 2020.
2020 is the fourth year for the Quality Payment Program (QPP). Many radiation oncologists will continue to participate in the Merit-based Incentive Payment System (MIPS) even with the pending radiation oncology-specific Advanced Alternative Payment Model (RO-Model). Based on an eligible clinician’s performance in four categories in 2019, their 2021 Medicare Part B reimbursement will be impacted.
In preparation for MIPS, you need to answer the following questions:
- What’s new this year?
- Am I eligible?
- How do I want to participate in 2020?
- How do I want to submit the data to CMS?
- Are there any bonuses?
New in 2020
An eligible clinician or group’s overall payment adjustment is based on the Composite Performance Score (CPS). For 2020, the CPS score is based on four performance categories: Quality, Promoting Interoperability, Improvement Activities and Cost. There are specific circumstances where a practice may not qualify for a certain performance category. For those cases, CMS has created reweighting scenarios, shown in this table.
||The Quality performance category typically comprises 45 percent of the CPS. Six quality measures are required unless your practice chooses to report the radiation oncology measure set. Data completeness rules for 2020 require a full year of reporting and at least 70 percent of patients that meet the measure’s denominator criteria, regardless of payer, with a minimum of 20 cases.
||The Promoting Interoperability (PI) performance category comprises 25 percent of the CPS. Hospital-based clinicians are exempt from this category and non-hospital based clinicians can apply for a hardship exemption based on certain criteria. An exemption or hardship reduces the PI category to zero and increases the Quality category weight. All reporting practices must utilize 2015 CEHRT.
||The Improvement Activities (IA) performance category comprises 15 percent of the CPS. Activities are weighted as medium, worth 10 points, or high, worth 20 points. Clinicians must complete activities for at least 90 consecutive days. The number of activities/points needed depends on practice location and size. RO-ILS and APEx can help satisfy the IA category requirements.
||The Cost performance category comprises 15 percent of final score in 2020. There are currently two cost measures in the performance category: Medicare Spending Per Beneficiary (MSPB) and Total Per Capita Cost (TPCC). Providers do not report data, as CMS will use administrative claims to attribute patients and costs to providers. If CMS cannot calculate a cost score for a physician/group, then the Cost category is reduced to zero.