QPP Year 3 Final Rule: What MIPS ECs Need to Know

November 07, 2018

Last week CMS released the QPP Final Rule outlining what the changing and expanding MIPS program will look like in its third year (2019).

Eligibility Changes:

  • Expands eligibility to include physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutrition professionals.
  • Adds a third element, number of covered professional services, to the low-volume threshold. In year 3, clinicians can be excluded if they provide 200 or fewer covered professional services (up from 100 in year 2)
  • Raises the low-volume threshold to include clinicians billing $90,000 in Medicare Part B charges (up from $30,000 in year 2)
  • Includes opt-in participation for clinicians meeting or exceeding at least one of the low-volume threshold criteria (clinicians do not have to meet or exceed all three criteria to opt-in).

Scoring Changes:

  • Updates to two of the four performance category weights. Quality = 45 percent (down from 50 percent in year 2); Cost = 15 percent (up from 10 percent in year 2); Improvement Activities = 15 percent; and Promoting Interoperability = 25 percent.
  • Creates a scoring option that enables facility-based clinicians to report facility-based data for Quality and Cost performance measures.
  • Moves clinicians to a smaller set of objectives and measures with scoring based on performance for the Promoting Interoperability category.
  • Continues the small practice bonus, but moves it to the Quality performance category score instead of as a standalone bonus.

APM Changes*: 

  • Streamlines the definition of a MIPS comparable measure for both Advanced APMs to reduce confusion and burden
  • Updates the APM measure sets that apply for purposes of the APM scoring standard.
  • Increases the certified EHR technology (CEHRT) use threshold; requiring 75 percent of ECs document care via CEHRT (up from 50 percent in 2018).
  • Extends the 8 percent revenue-based nominal amount standard through performance year 2024.

*Changes apply to both Advanced APMs and Other Payer Advanced APMs.

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