FEBRUARY 3, 2020

Welcome to the MACRA MIPS/APM Update eNewsletter
Editor: Philip L. Ronning
This issue is sponsored by the National ACO Summit, the National Bundled Payment Summit,
the National Medical Home Summit, the National MACRA MIPS/APM Summit,
and the National Medicare Advantage Summit

MIPS 2020: Complete Guide
CMS released the 2020 Final Rule for the Quality Payment Program on Friday November 1, 2019. You can read the full 2,475-page rule here: CY 2020 Medicare Physician Fee Schedule (PFS) Final Rule. Alternatively, this guide identifies everything you need to know about MIPS 2020. CMS described their changes to the MIPS 2020 program as changes that "…will gradually prepare clinicians for the MIPS 2022 performance period." CMS said that because MIPS 2022 is the first year of the full implementation of MIPS.

While MIPS 2017 was the first year of MIPS, it was not the first year of the full implementation of MIPS. The first five years of MIPS, meaning 2017 through 2021, are transition years. That means that core components of the MIPS program are just ramping up during these years. And the changes in MIPS 2020 are a part of that ramp. Here's what you'll learn in this guide:

  • What's changing in MIPS 2020
    • Scoring
      • Category weights
      • Performance thresholds
    • Payment adjustments
    • Category requirements
      • Quality
      • Cost
      • Promoting Interoperability
      • Improvement Activities
  • What's not changing in MIPS 2020
  • What's changing after MIPS 2020
    • Category weights
    • Performance thresholds
    • MIPS Value Pathways (MVPs)

CMS did not finalize any of its proposed changes to MIPS category weights in MIPS 2020. For that reason, the Quality category will still be worth 45% of the MIPS composite score in MIPS 2020. And the cost category will still be worth 15% of the MIPS composite score.

(Able Health, access January 7, 2020)

98% of MIPS Clinicians Earned a Bonus for 2020—But Don't Expect a Big Payout
More clinicians participated in MACRA's Advanced Alternative Payment Model (Advanced APM) track and Merit-based Incentive Payment System (MIPS) in 2018, and more participating clinicians will receive positive payment adjustments, CMS Administrator Seema Verma wrote Monday in a blog post.


Under MACRA's Quality Payment Program (QPP), which took effect in 2017, eligible clinicians can choose from two payment tracks:

  • The Advanced APM track, for clinicians who take on a significant portfolio of Advanced APMs, which include risk-based accountable care organization (ACO) models; or
  • MIPS, for providers who are reimbursed largely through fee-for-service.

Clinicians' pay in the MIPS track largely follows a traditional fee-for-service structure, but CMS adjusts eligible clinicians' pay based on how they "score" in four categories of metrics:

  • Cost;
  • Improvement activities;
  • Promoting interoperability, formerly called Advancing care information (ACI); and
  • Quality.

But for the 2020 payment year, which is based on 2018 data, eligible clinicians needed to report on a full year's worth of quality data, and CMS increased the performance threshold to 15 points for providers to avoid the 5% penalty, applied to payments in 2020. Beginning in the 2021 performance period, the new MIPS Value Pathways (MVP) participation framework will seek to overhaul MIPS reporting to reduce burden and make the program more meaningful for participating clinicians and patients.

(Advisory Board, January 7, 2020)

The New MACRA Medigap Deductible Rules are Here
A change in the Medicare supplement insurance deductible rules took effect Wednesday, after years of waiting and planning. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) now forbids many consumers from buying new Medicare supplement insurance policies that pay the Medicare Part B deductible. The 2020 Medicare Part B deductible is $198. The MACRA change means that the consumers who are affected by the change must pay the $198 Medicare Part B deductible themselves, without help from their Medicare supplement insurance coverage. But Bonnie Burns pointed out in November, in an article for ThinkAdvisor.com, that figuring out which consumers are actually affected by the new MACRA rules will be a little complicated. (ThinkAdvisor, January 2, 2020)

[Slideshow]: MIPS 2020 Changes from the Final Rule
CMS released the 2020 Physician Fee Schedule (PFS) final rule which contained the revised MIPS requirements. Next year CMS is upping the minimum score requirements and plan to post your 2018 MIPS performance to Physician Compare. Also, of note, CMS has released its vision for how their new MIPS Value Pathways (MVP) program may look in 2021. I've summarized the gist of the program below the slideshow.

(Medisolv, accessed January 9, 2020)

CMS: MIPS Positive Payment Adjustments Increase in 2020
Ninety-eight percent of eligible clinicians participating in the Merit Based Incentive Payments System (MIPS) will receive a positive payment adjustment in 2020, a five percentage point increase since MIPS began, according to the Centers for Medicare & Medicaid Services. This comes as the MIPS Value Pathways (MVPs) are set to launch in 2021, a change to the original Medicare Access and CHIP Reauthorization Act (MACRA) that CMS says will streamline quality reporting and "cut government red tape." With MIPS Value Pathways (MVPs) set to launch in 2021, CMS announced the preliminary participation data from 2018 for eligible MIPS clinician participants. That 98 percent figure is also a 5-point increase from 2017 and an overall increase from 3 points in 2017 to 15 points in 2018. More rural and small practices will also receive positive payment adjustments, suggesting that any provider – large or small, rural or urban – can succeed in this program, CMS said. A 4 percent increase in positive payment adjustments from rural practices occurred from 2017 to 2018, jumping from 93 percent to 97 percent. When talking about small practices, 84 percent of eligible clinicians received a positive payment adjustment. This number increased 10 percent from 2017. Overall, 889,995 clinicians received a MIPS payment adjustment and out of that number, 872,148 received a neutral or positive payment adjustment. This is 3 percent overall increase from 2017 and a 3 percent increase in neutral or positive adjustments. (EHR Intelligence, January 7, 2020)

More Physicians Shift from MIPS to APMS in Medicare
The number of physicians receiving Medicare payments through risk-based models sharply increased in 2018, while the much larger number for whom payment is based on quality-measure performance started to decline. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established criteria for Medicare to pay physicians through either the Merit-based Incentive Payment System (MIPS) or advanced alternative payment models (APMs). MIPS requires annual quality reporting to garner bonuses, avoid cuts or maintain payment levels, while APM participants generally garner 5% annual pay increases. The simplified APM approach, in which the convening organization can collect and report clinician data on behalf of participating clinicians, appears to be drawing increasing physician interest.

The latest MACRA results showed that:

  • APM participation increased by 84% to more than 183,000.
  • MIPS participation decreased by 5% to nearly 890,000.
  • Of physicians paid through MIPS, 97% received a bonus payment of as much as 1.68%.
  • Of physicians paid through MIPS, 2% were dealt payment cuts of as much as 5%.

Among closely watched categories of participants that are considered vulnerable to payment cuts, 97% in rural practices garnered a bonus (compared with 93% in 2017), and 84% of small practices received a bonus (versus 74% in 2017). (HFMA, January 8, 2020)

2020 MIPS Summary Cost Measures

MACRA MIPS/APM Update e-Newsletter is one of a family of free e-Newsletters providing a complimentary video presentation and regularly updated news and key resources on major health care issues such as ACOs, patient safety, pay for performance, bundled payment, readmissions, and Medicaid. To view and subscribe to other e-Newsletters go to healthcareeNewsletters.com.

Value-based Payment, Technology, and the Future of Customer Service

Mark D. Smith, MD, MBA
Co-chair, Guiding Committee, Health Care Payment Learning and Action Network; Clinical Faculty, University of California, San Francisco; Attending Physician, Positive Health Program for AIDS Care, San Francisco General Hospital; Founding President and CEO, California Health Care Foundation, San Francisco, CA