Risk Adjusted Coding: Improvement Activities and Promoting Interoperability Performance Measures of MIPS 2020
Date Posted: Thursday,
March 12, 2020
MIPS is the program that will determine Medicare payment adjustments. Using a composite performance score, eligible clinicians (ECs) may receive a payment bonus, a payment penalty, or no payment adjustment. Improvement activities account for 15% of the total MIPS score and promoting interoperability accounts for 25%. Both proportions are unchanged from 2019.
If a group is identified as hospital-based, it is eligible when more than 75% of the NPIs in the group meet the definition of hospital-based MIPS eligible clinicians (100% in 2019). The maximum incentive/penalty for 2020 is +9% or -9% applied in 2022. In the Final Rule, the Negative Adjustment Threshold (points scored) is 45 points (up from 30 in 2019) and the performance bonus threshold is 85 points (up from 75 in 2019.) One can earn up to 40 points in improvement activities and up to 100 points in promoting interoperability.
CMS confirmed that they did not propose any changes to the following policies for MIPS in 2020:
- MIPS eligibility: low-volume thresholds; i.e., if one does not bill more than $90,000 in covered Part B professional services and see more than 200 Part B patients and provide 200 or more covered professional services to Part B patients; and opting out of the program, eligible clinician types, opt-in policy, MIPS determination period
- Data collection and submission: MIPS performance period, collection types, submitter types, submission types, CEHRT requirements
- Quality Measures: topped-out measures, measures impacted by clinical guideline changes
- Facility-based clinicians: definition and determination, scoring methodology, and policies.
Of the 105 improvement activities for 2020, 15 were deleted, seven changed, and two added. There was no change to the weights associated with each activity; medium is worth 10 points and high weight is worth 20 points. One must earn 40 points, which could be a combination of four medium, two high, or one high and two medium worth activities. There were some improvement activities which only require attestation with a “yes” when completed. For an activity to count for a group, there must be at least 50% of the clinicians participating in the same activity for > 90 days.
For the promoting interoperability category, participants must use the 2015 Edition Certified EHR Technology (CEHRT). There is no change to e-prescribing, health information exchange, provider to patient exchange, public health and clinical data exchange (Note: If your state cannot exchange data through their public health system, you must have proper evidence of this), and the five mandatory performance measures. Participants must perform the security risk analysis. There is still a 90-365-day performance period and removal of the verification of opioid treatment agreement measure, which was optional in 2019.
Changes to improvement activities include the expansion of the choice of patient centered medical home recognition. It can now be any certifying body with national scope and at least >500 certified entities. Two additional activities and 15 activities were removed. For an activity to be counted, there must be at least 50% of clinicians in the group participating in the same activity, each for > 90 days. CMS has also established criteria for removal of activities. There are two new improvement activities: IA_BE_25 Drug Cost Transparency (High Weighting) and 20 tracking the clinician's relationship to and responsibility for patient reporting by reporting MACRA patient relationship codes (high weighting); this requires modifiers to be submitted with
HCPCS codes. CMS modified 7 improvement activities:
- Completion of an accredited safety or quality improvement program
- Anticoagulant management improvements
- Additional improvements in access as a result of QIN/QIO TA
- Implementation of formal quality improvement methods, practice changes, or other practice improvement processes
- Participation in a QCDR, that promotes use of patient engagement tools
- Use of QCDR data for ongoing practice assessment and improvements
- Completion of Collaborative Care Management Training Program
Participation in Systematic Anticoagulation Program:
- Implementation of additional activity as a result of TA for improving care coordination
- Participation in Quality Improvement Initiatives
- Annual Registration in the Prescription Drug Monitoring Program
- Initiate CDC Training on Antibiotic Stewardship
- Unhealthy alcohol use
- Participation in a QCDR, that promotes use of processes and tools that engage patients for adherence to treatment plan
- Use of QCDR to support clinical decision making
- Use of QCDR patient experience data to inform and advance improvements in beneficiary
- Participation in a QCDR, that promotes implementation of patient self-action plans
- Use of QCDR to promote standard practices, tools and processes in practice for improvement in care coordination
- Leveraging a QCDR for use of standard questionnaires
- Leveraging a QCDR to standardize processes for screening
- Use of QCDR data for quality improvement, such as comparative analysis reports across patient populations
- CPI Participation
Promoting Interoperability had two significant changes: one bonus measure was removed and the definition of a hospital-based group changed. CMS removed the verification of opioid treatment agreement measure in MIPS 2020. However, CMS kept the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional bonus measure. There are changes to Hospital Based MIPS Eligible Clinicians in groups. For inpatient hospital (POS 21), on campus outpatient hospital (POS 22), off campus outpatient hospital (POS 19), and Emergency room (POS 23), only 75% of NPIs in TIN are defined as hospital based. For these clinicians, CMS will use either the favorable facility-based score or the NPI score.
Reporting is still a 90-365-day performance period. Starting next year, groups earn credit for an improvement activity if at least 50% of clinicians fulfill the activity during a 90-day period within the performance year.
E-prescribing is now worth 10 points. Other highlights include exclusions for sending electronic health data.
Objectives Measures Maximum Points
Maxine Lewis, CMM, CPC, CPC-I, CPMA, CCS-P, is a member of the National Society of Certified Business Consultants and is a nationally recognized lecturer, author, and consultant in the healthcare industry, combining more than 40 years of practical experience in the medical office with an in-depth understanding of coding, reimbursement, and management issues of the medical profession.
