Eligible physicians who fail to report data under Medicare’s 2019 Quality Payment Program (QPP) will be subject to a 7% penalty in 2021. That penalty will rise to 9% the following year.

To avoid such penalties, physicians need to score a minimum of 30 points in this year’s iteration of the QPP’s Merit-based Incentive Payment System (MIPS). The AMA’s expert resources outline what’s new this year under MIPS and how you can avoid potential future pay cuts.

The AMA offers extensive resources to help physicians understand MIPS, including:

Those physicians seeking a positive payment adjustment to their Medicare rates (potentially up to 7%) should have already started collecting data for the MIPS Quality performance category as of Jan. 1. Physicians, however, looking to avoid penalties and receive a neutral Medicare pay adjustment can still do so by collecting 90 days’ worth of data relevant to the MIPS Promoting Interoperability (PI) and Improvement Activities (IA) categories. The latest date to begin collecting data is Oct. 1.

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New requirements on 90-day MIPS reporting

The AMA’s resources detail PI and IA scoring for those seeking to meet minimum 90-day reporting requirements to avoid a penalty.

In the PI category, formerly called Advancing Care Information, one major new requirement is that MIPS-eligible physicians must use 2015-edition Certified Electronic Health Record Technology (CEHRT) to report performance on PI measures.

Measures in this category align with four objectives:

  • e-Prescribing.
  • Health information exchange.
  • Provider-to-patient exchange.
  • Public health and clinical data exchange.

Six new activities have been added to the CMS list of more than 100 approved 2019 MIPS IAs that physicians and groups can choose from. They are divided into nine subcategories.

  • Expanded practice access.
  • Population management.
  • Care coordination.
  • Beneficiary engagement.
  • Patient safety and practice assessment.
  • Participation in an APM.
  • Achieving health equity.
  • Emergency preparedness and response.
  • Integrated behavioral and mental health.

Physicians and groups operating as a patient-centered medical home or a comparable specialty practice automatically earn maximum IA points, as do those participating in the CMS study on factors associated with reporting quality measures. Small and rural practices, nonpatient facing physicians and those practicing in a Health Professional Shortage Area receive double the points for all IAs.

Physicians, groups and virtual groups can log in on the CMS QPP website to attest to their performance in the IA category. The CMS notes that these entities can be subject to selective audits.

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