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.
2019 is the third year for the Quality Payment Program (QPP). Most radiation oncologists will participate in the Merit-based Incentive Payment System (MIPS). 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 2019?
- How do I want to submit the data to CMS?
- Are there any bonuses?
New in 2019
An eligible clinician or group’s overall payment adjustment is based on the Composite Performance Score (CPS). For 2019, the CPS score is based on four performance categories: Quality, Promoting Interoperability, Improvement Activities and Cost.
||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 2019 require a full year of reporting and at least 60 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. In 2019, a practice 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. Clinicians simply need to attest to completing the activities. RO-ILS and APEx can help satisfy the IA category requirements.
||The Cost performance category comprises 15 percent of the CPS weight in 2019. 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 and the weight of the Quality category increases from 45 to 60 percent.