In mid-August, the Centers for Medicare & Medicaid Services (CMS) released its 2020 Quality Payment Program Proposed Rule Overview. This document outlines changes to Quality Payment Program (QPP) policies that will take effect in the upcoming 2020 year, as well as proposed changes for 2021. It is also a summarization of the far more detailed (and roughly 1700 page long) CY 2020 Revisions to Payment Policies document. One section that is likely to be of the most interest to healthcare providers deals with new modifications to the Merit-Based Incentive Payment System (MIPS). In this article, we will be looking at these MIPS 2020 changes, particularly those that are of concern to specialty healthcare practices in fields such as dermatology, ophthalmology, plastics/aesthetics and orthopedics.
While there are many changes that apply to specialty practices, there are also several general changes that will apply to everyone. Before we get into the specialty-specific changes, let’s first look at some of the new rules that everyone needs to know:
- The minimum Performance Threshold score has been increased to 45 points (from 30 points).
- The Additional Performance score threshold, which must be met/exceeded to qualify for Exceptional Performance, has been raised to 80 points (from 75 points).
- The maximum Negative Payment Adjustment, for scoring below the minimum performance threshold, has been changed to -9 percent (from -7 percent).
- The maximum Positive Payment Adjustment has increased to 9 percent (from 7 percent). As before, this adjustment does not include additional positive adjustments for those who qualify for exceptional performance.
- Quality now makes up 40 percent of the overall score (down from 45 percent), in addition to some measure changes. Each measure must be reported on at least 70 percent of cases (up from 60 percent).
- For Quality scoring, 70 percent of cases must be reported. Selectively choosing which cases to report (in order to obtain a higher score) is strictly prohibited; additionally, submitting reports for any less than 70 percent will result in 0 points for the Quality measure.
- Cost now makes up 20 percent of the overall score (up from 15 percent)
- Promoting Interoperability (25 percent) and Improvement Activities (15 percent) remain unchanged.
- For an Improvement Activity to qualify as part of the IA score, 50 percent or more of the providers in a group must participate in that activity (for example, in a practice with three providers, an activity participated in by just one provider would not be counted).
- The Verify Opioid Treatment Agreement measure of PDMP has been removed, and the opioid measure for querying PDMP will continue to be optional.
- Several measures having to do with Quality Clinical Data Registries have been removed and are now integrated into the remaining two measures (see page 12 of this document for details).
Quality Measure Changes for Specialty Practices
The following changes have been made to the Quality measure, and should be noted depending on specialty:
- BCC/SCC Reporting Time (440) – melanoma diagnosis codes added to the denominator
- Cataract Surgery 20/40 Vision (191) – wording changed to ensure doctors are reporting per case/eye, as opposed to per patient as done in the past
- Diabetes Eye Exam (117) – an exclusion has been added for some patients and the timing has been changed to 12 months for patients with DR and 24 months for patients without DR
- DR Communication (19) – Claims-based reporting is no longer supported
- Psoriasis TB Prevention (337) – now requires testing before treatment
- RD Surgery VA (385) – there is a new exclusion for patients who already have at least 20/40 Visual Acuity (VA)
Changes to PI in Specialty Practices
The following changes have been made to the Promoting Interoperability (PI) measure, and should be noted depending on specialty:
- If using the Sending Health Information (C-CDA) exclusion, points will now be distributed to the Provide Patient Access measure
- Receiving and Incorporating exclusion now includes all new patients, whether or not the note was sent to you electronically
Changes to IA in Specialty Practices
The following change has been made to the Improvement Activities (IA) measure, and should be noted depending on specialty:
- The TCPI Participation program will come to an end in 2019, and has been removed for the 2020 year
A New Cost/TPCC Exclusion for Specialty Practices
The following change has been made to the Total Per Capita Cost (TPCC) measure, and should be noted depending on specialty:
- Several specialties have now been excluded from the TPCC measure—Dermatology, Ophthalmology, Optometry, and Plastic Surgery
As we move closer to 2020, it is important to begin preparing your practice’s staff and updating its reporting methods to make sure you continue to qualify for MIPS compensation under these new changes. A little preparation done now is likely to save you a lot of headaches in the future. For specialty practices using Nextech, please contact your Customer Service Representative with any questions or concerns you might have. If you would like to discover how Nextech can help your practice maintain compliance, please use the comments section below to contact us or click here to schedule a demonstration.
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