CMS Proposes Changes to MIPS in 2020 - What Does it Mean for You?

Posted on August 1, 2019

The Centers for Medicare and Medicaid Services (CMS) has released its proposed rule for the Quality Payment Program (QPP), with several proposed changes to MIPS in 2020 and future reporting years. A final rule will be released later this fall after a public comment period. The proposed rule would continue to gradually increase the reporting requirements under the MIPS program. In this article we will highlight the most important proposed changes you need to know for the 2020 performance year and how they could impact your bottom line. We will also cover how CMS plans to transform the program in 2021 to reduce your reporting burden.

Higher Performance Thresholds and Penalties

CMS proposes to increase the performance threshold which is the number of MIPS points needed to avoid any penalties. The threshold would increase to 45 MIPS points in 2020 (up from 30 points in 2019), and 60 MIPS points in 2021. Additionally, the exceptional performance threshold to achieve a bonus would increase from 75 MIPS points in 2019 to 80 MIPS points in 2020 and 85 MIPS points in 2021.

There would also be greater financial implications for MIPS eligible clinicians who choose not to report. The maximum penalty for not reporting in 2020 would rise to negative -9% (up from -7% this year). While payment adjustments would range from -9% to +9%, any positive payment adjustments are expected to be below 9% due to the federal budget neutrality requirements.

Performance Categories 

Category Weights

The Quality and Cost category weights would change to move towards equal weighting by 2022:

QualityCostPromoting InteroperabilityImprovement Activities
  • 40% in 2020
  • 35% in 2021
  • 30% in 2022
  • 20% in 2020
  • 25% in 2021
  • 30% in 2022
Remains at 25%Remains at 15%


The data completeness requirements would increase from 60% to 70% beginning in 2020. This means Quality measures would need to be reported on at least 70% of eligible cases, for both Medicare and non-Medicare patients, for the entire year. Measures that are submitted, but do not meet the data completeness threshold (even if they have a measure benchmark and/or meet the 20 case minimum), would receive 0 points (instead of 1 point in 2019). Clinicians in small practices (15 or less in the TIN) would continue to receive 3 points for measures that don’t meet the data completeness requirements.

Additional proposed changes include:

  • Removing some Quality measures (e.g., those not meeting case minimum/reporting volumes needed for benchmarking for 2 consecutive years or measures that are not available for reporting by or on behalf of all MIPS eligible clinicians).
  • Adding new specialty sets for Speech Language Pathology, Audiology, Clinical Social Work, Chiropractic Medicine, Pulmonology, Nutrition/Dietician, and Endocrinology.
  • Establishing flat percentage benchmarks for limited cases where CMS determines that the measure’s benchmark could potentially incentivize inappropriate treatment for some patients.

Promoting Interoperability (PI)

CMS is not proposing any significant changes to the PI category in 2020. The proposed rule would consider a group as hospital-based and eligible for reweighting if more than 75% of the clinicians in the group meet the definition of a hospital-based individual MIPS eligible clinician (it is currently 100%).

Additional proposed changes include:

  • Beginning with the 2019 performance period, CMS would:
    • Allow clinicians to satisfy the optional Query of Prescription Drug Monitoring Program (PDMP) measure with a yes/no response instead of a numerator/denominator;
    • Redistribute the points for the Support Electronic Referral Loops by Sending Health Information measure to the Provide Patients Access to Their Health Information measure if an exclusion is claimed.
  • Beginning with the 2020 performance period, CMS would remove the Verify Opioid Treatment Agreement measure and keep the Query of PDMP measure as optional.

Improvement Activities (IA)

CMS proposes to increase the participation threshold for group reporting from a single clinician to 50% of the clinicians in the practice for the Improvement Activities category.

Additional proposed changes include:

  • Modifying the definition of rural area to mean a ZIP code designated as rural by the Federal Office of Rural Health Policy (FORHP) using the most recent FORHP Eligible ZIP Code file available.
  • Updating the IA inventory and establishing criteria for removing activities in the future.
  • Concluding the CMS Study on Factors Associated with Reporting Quality Measures.
  • Removing criteria for Patient-Centered Medical Home designation that a practice must have received accreditation from one of 4 accreditation organizations that are nationally recognized or comparable specialty practice that has received the NCQA Patient-Centered Specialty Recognition.


CMS proposes to add 10 new episode-based measures to the Cost category and revise the current measures – Medicare Spending Per Beneficiary Clinician measure and Total Per Capita Cost measure.

MIPS Value Pathways (MVP)

CMS also proposes a new framework to transform the MIPS program beginning with the 2021 performance year called the MIPS Value Pathways. The agency stated that under MVPs, clinicians would report on a smaller set of measures that are specialty-specific, outcome-based, and more closely aligned to Alternative Payment Models (APMs). The goal of MVPs is to move towards an aligned set of measures more relevant to a clinician’s scope of practice across all MIPS performance categories for different specialties or conditions.

CMS created some illustrative diagrams regarding the MIPS Value Pathways:

MIPS Value Pathways Diagram

MIPS Value Pathways Surgery Example 

MIPS Value Pathways Diabetes Example

Looking Ahead

MIPS eligible clinicians and groups should continue to stay on top of their 2019 MIPS data reporting, but become familiar with proposed changes for the 2020 reporting year. The QPP Proposed Rule would establish higher performance thresholds and payment adjustments next year, so more reporting and planning will be necessary to avoid any penalties. Since this is a proposed rule with a public comment period, some provisions could change when a final rule is released in the coming months. Additional information about the proposed rule can be found in the CMS Fact Sheet here.

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MACRA 2020 MIPS Proposed Rule MIPS Reporting MIPS Value Pathway

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