September 20, 2018

MIPS Performance Categories—Proposed Changes in the 2019 Medicare Physician Fee Schedule Proposed Rule

On July 12, the Centers for Medicare & Medicaid Services (CMS) published its 2019 Medicare Physician Fee Schedule Proposed Rule (Proposed Rule) covering a wide range of topics.  In our series of articles, we have summarized and offered our insights on several key provisions.  Note that comments on the Proposed Rule were due to CMS by September 10, 2018, and we expect CMS to publish the Final Rule later this fall.   Of the 15,313 comments CMS received on the Proposed Rule, 1,212 of them included the acronym MIPS.  You can review all the comments here

In addition to the usual updates to Part B payment policies, the Proposed Rule includes numerous changes to the Quality Payment Program (QPP).  With regard to MIPS—the Merit-Based Incentive Payment System—CMS continues to implement the program per statutory requirements, while streamlining processes and reducing burden.

The following summarizes CMS’ proposed changes to the specific performance measures in each of the four MIPS categories (Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly known as Advancing Care Information, which was the successor to Meaningful Use).  In a separate article, we address the seven most important proposed changes to MIPS’s scope and application.

For those wishing to take a deeper dive, CMS has published a 28-page fact sheet detailing its proposed changes to the QPP for 2019.


For 2019, CMS proposes to re-weight the Quality category at 45% of the overall MIPS score (down from 50%).  The five percentage points removed from the Quality bucket would be re-allocated to the Cost category (resulting in an increase in that category from the current 10% weight to 15%).  CMS proposes the minimum performance period for the Quality category remain at 12 months.

For 2017 and 2018, Eligible Clinicians (ECs), groups, and virtual groups must use the same reporting mechanism (e.g., claims, registry, EHR) for all quality measures.  For most measures, the benchmark varies depending on the selected reporting mechanism; thus, the same level of performance can net a different score based on the reporting mechanism utilized.  As a result, much time and effort have been spent identifying the optimal combination of measures for a selected reporting mechanism.

CMS now proposes to permit the use of multiple reporting mechanisms for the submission of quality data in 2019, including reporting on the same measure using multiple mechanisms.  In that case, CMS would use the highest score across the multiple mechanisms to calculate the overall Quality score.

CMS also proposes to change the manner in which the small practice bonus is applied.  For 2018, a five-point bonus is added to the final MIPS score for qualifying ECs, groups, and virtual groups that submit data in at least one performance category.  For 2019, CMS proposes to add a three-point bonus to the Quality numerator for qualifying ECs, groups, and virtual groups that submit data in the Quality category.


As noted above, CMS proposes re-weighting the Cost category from 10% to 15%.  CMS will continue to calculate scores using claims data; no additional reporting is required for ECs or groups.  CMS proposes the minimum performance period for the Cost category remain at 12 months.

In addition to the current Total Per Capita Cost Medicare Spending Per Beneficiary measures, CMS proposes to add eight procedural and acute inpatient medical care episodes.  Unlike the current measures, which are attributed to an EC or group based on the plurality of primary care services, these new measures will be attributed based on direct involvement in the episode of care.

CMS had intended to add improvement scoring to the Cost category beginning in 2018, rewarding providers who demonstrated a reduction in costs as compared to prior years.  However, the Bipartisan Budget Act of 2018 delayed consideration of improvement in the Cost category until 2022.

Improvement Activities

CMS proposes maintaining the weight to final score of the Improvement Activity category at 15% and the minimum performance period at 90 days.  As proposed, the inventory of activities would include six new and five modified activities, with one activity deleted.  Also, the Promoting Interoperability bonus would be removed.

Promoting Interoperability (formerly Advancing Care Information)

For 2019, CMS proposes maintaining the weight to final score of the Promoting Interoperability category at 25% and the minimum performance period at 90 days.  CMS intends to continue to re-weight this category to 0% for certain types of providers and in certain circumstances, and would expand the types of providers to include new ECs (including physical therapists, occupational therapists, clinical social workers, and clinical psychologists).

CMS proposes ECs must use the 2015 edition of Certified EHR Technology, or CEHRT.  The option of using the 2014 edition or a combination of the two would be discontinued.

CMS proposes eliminating the base and performance categories and replacing them with scoring at the individual measure level under each category.  Similar to the 2018 performance year, eligible clinicians will be required to report certain measures from each of the following four objectives:

  • E-prescribing
  • Health Information
  • Provider-to-Patient Exchange
  • Public Health and Clinical Data Exchange

However, for the 2019 performance period, CMS proposes adding two new measures to e-prescribing:

  • Query of Prescription Drug Monitoring Program
  • Verify Opioid Treatment Agreement

PYA assists providers in navigating the complex MIPS requirements and maximizing performance.  Contact a PYA executive below for more information at (800) 270-9629.



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