Outrunning The MIPS Bear in 2019

Well hello again!  Remember MIPS, which is a program under QPP?  It’s still here, and we still gotta tackle it by outrunning Da MIPS Bear in 2019.  Still gotta be a bit faster than the next slowest guy.  We should still shooting to be in the middle group of folks who are faster than the slowest guys ahead of Da MIPs Bear.

Why make sure you’re not the slowest guy?  Good question!  Because if you are, you’ll pay the penalty even though you’re being a good compliant doctor, participating minimally whether you like it or not.  Da Bear is after you regardless: first he’s going to savage those who don’t participate in MIPs at all, and then he’s going to go after those who bother to meet only minimum thresholds.  They’re too slow – don’t be too slow.

Ok, what’s changed from 2018 to 2019?  Well, there are still 4 categories to consider: 1) Quality, 2) Promoting Interoperability (PI), 3) Improvement Activities (IA), 4) Cost.

Quality: changed from 50% to 45% of your final score

Quality replaced PQRS.  Just like PQRS, you’ve got to figure out which Clinical Quality Measures (CQM) you’re going to focus on: you need 6 that best fit your practice and report on a full year.

  • Submit collected data for at least 6 measures, or a complete specialty measure set; and
  • One of these measures should be an outcome measure; if you have no applicable outcome measure, you can submit another high priority measure instead
  • You can get 6 bonus points using a certified EMR

Promoting Interoperability (PI): 25% of your final score, unchanged, but requirements changed

I like this nugget: 2015 Edition CEHRT is required for participation in this performance category.  Ah ha!  Is your EHR 2015 certified?  I’ll show you where to verify that info for your EHR.

You’ve got to submit 4 objectives over 90 days or more. In addition to submitting measures, clinicians must:

  • Submit a “yes” to the Prevention of Information Blocking Attestation,
  • Submit a “yes” to the ONC Direct Review Attestation; and
  • Submit a “yes” for the security risk analysis measure
  • 5 bonus points each for the submission of these optional measures:
    • Query of Prescription Drug Monitoring (PDMP)
    • Verify Opioid Treatment Agreement

Improvement Activities: 15% of your final score

To earn full credit in this performance category, participants must submit one of the following combinations of activities (each activity must be performed for 90 continuous days or more during 2019):

  • 2 high-weighted activities
  • 1 high-weighted activity and 2 medium-weighted activities
  • 4 medium-weighted activities

Cost Measure: Changed from 10% to 15% of your final score

The good news: Cost measures are evaluated automatically via claims data and are based on Medicare Spending per Beneficiary and Total per Capita Cost.  CMS, by raising the percentage, is obviously trying to reduce bureaucratic overhead on clinics.  Feel grateful?

There you have it – MIPS is designed to push you towards ever more meaningful use of your EMR.  There’s no minimum qualifying threshold that’ll remove you as bear bait.  Adopt the workflows in your EMR to constantly improve your scores – that’s the best way to go!