MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2020 will impact Medicare payments in 2022). In 2020, the adjustments will potentially range from –9 percent to +9 percent. In order to be eligible for a positive adjustment, a clinician’s score must exceed a certain threshold, which is 30 points in 2019, 45 points in 2020, and 60 points in 2021. There is also an exceptional bonus for high performers, which CMS has set at 75 points in 2019 and 85 points in 2020 and 2021.
To meet this requirement, most emergency physicians will have to report on six measures over a 12-month period. The Quality category will count for 45 percent of your total score in 2020. One great way to meet the Quality requirement is by reporting through a qualified clinical data registry (QCDR). ACEP has developed its own QCDR, called the Clinical Emergency Data Registry (CEDR). Another option available to emergency physicians for meeting the Quality category is the “facility-based scoring option.” See below for more details.
Cost is automatically calculated by CMS based on two major measures: the Medicare Spending Per Beneficiary (MSPB) measure and the Total Per Capita Cost measure, as well as a set of episode-based measures. Cost will represent 15 percent of your total score in 2020. If these measures do not apply to you or your practice, you will not receive a cost score and your quality score will count for 60 percent of your total score. Another option available to emergency physicians for meeting the Cost category is the “facility-based scoring option.” See below for more details.
This category rewards participation in activities that improve clinical practice. There is a list of activities that are classified as either medium or high-weighted based on their value to patient care. To earn full credit in this category, participants must submit one of the following combinations of activities (each activity must be performed for 90 days or more during 2020):
Starting in 2020, groups can only attest to an improvement activity if at least 50 percent of clinicians in the group participate in or perform the activity. Previously, a group could attest to an improvement activity if at least one clinician in the group participated in or performed the activity.
A great way to meet the requirements of this performance category is by participating in ACEP’s Emergency Quality Network (E-QUAL) Initiative.
This category includes measures and objectives related to the use of electronic health records (EHRs). Most emergency physicians are exempt from this category (formally known as the “Meaningful Use” program) because they are “hospital-based” clinicians who use their hospital’s EHR. Recently, ACEP achieved a major victory related to this exemption. Starting in 2020, CMS will exempt groups from the Promoting Interoperability category of MIPS as long as 75 percent of individuals in the group meet the definition of “hospital-based.” Previously, if individual clinicians had decided to report as part of a group, they lost the exemption status if just one group member did not meet the definition of “hospital-based.” ACEP had repeatedly argued that this “all-or-nothing” policy was unfair as it penalized hospital-based clinicians who work in multi-specialty groups.
One scoring option available to emergency physicians starting is called the facility-based scoring option for the Quality and Cost categories of MIPS.
With this scoring option, clinicians who deliver 75 percent or more of their Medicare Part B services in an inpatient hospital, on-campus outpatient hospital, or emergency room setting will automatically receive the quality and cost performance score for their hospital through the Hospital Value-based Purchasing (HVBP) Program. Most emergency physicians qualify for this option. Clinicians who qualify for the option can still report quality measures through another submission mechanism (such as a QCDR) and receive a “traditional” MIPS score for quality. If they do so, CMS will automatically take the highest of the HVBP score and the traditional MIPS score.