As eligible clinicians make their way towards the final quarter of the 2017 Performance Year for MIPS, the Centers for Medicare and Medicaid Services (CMS) has already proposed changes for the 2018 performance year. While they are working towards making life easier for smaller and rural practices through virtual groups and an increased low-volume threshold, they are also tightening the belt with respect to participation guidelines and scoring. In some instances, they chose to not make changes for 2018 at all, but rather to include the verbiage for changes that would affect the 2019 performance year. Here are some notable differences to be aware of.
Data Completeness: In the 2017 performance year, to have a quality measure be considered “complete” during the reporting period, you must submit at least 50% of Medicare Beneficiary data unless you are using the Web Interface or CAHPS. In 2018, that rule remains the same. However, CMS included verbiage stating that data completeness would be increased to at least 60% in 2019.
Quality Category Scoring: In 2017 eligible clinicians received a base of 3 points for simply submitting data for a quality measure. However, in 2018, if you do not submit “complete” data as described above, you will only receive 1 base point instead of three. Thankfully, no changes have been made to bonuses for additional high-priority measures and 100% electronic reporting.
Quality Category Weight: In 2017, the Quality Category counts as 60% of your total composite performance score (TCPS). That remains the same for the 2018 performance year. However, for 2019 CMS proposes the Quality Category only count as 30% of your TCPS, to make room for the Cost Category to be calculated and applied.
Cost Category Calculations: In 2017 and 2018, the Cost Category is calculated by CMS but does not count towards the TCPS. That all changes in 2019 where it makes a huge impact at 30% of the TCPS. Scores will be calculated based on the Medicare Spending per Beneficiary and the total per capita cost measures. CMS is also hoping to develop new episode-based cost measures with expert clinicians and other stakeholders.
Improvement Scoring: In 2017 there couldn’t be improvement scoring simply because it was the first year of MIPS. In 2018, CMS proposes to reward an improvement in performance. For the Quality Category, eligible clinicians will be rewarded a certain number of points based on their rate of improvement meaning those who improve the most will get more points. CMS is also seeking to develop improvement scoring for the Cost Category because, although it wasn’t applied to the TCPS, the score has been calculated all along. Because of this, they can see performance improvement and seek to reward that improvement during the 2019 performance year.
Look for our next article to see new guidelines for both the Improvement Activities and Advancing Care Information Categories. Additionally, new complex patient bonuses and scoring methodology will be applicable for the 2018 performance year.