The wait is over - the Centers for Medicare and Medicaid Services (CMS) has finally released the 2019 Quality Payment Program Final Rule  which takes effect on January 1, 2019. There are several changes to MIPS for the 2019 performance year. While providers are still working to complete their 2018 reporting requirements, it’s a good idea to become familiar with some of the changes ahead and understand how you might be impacted.

As we head into the final stretch of Year 2 of the Merit-Based Incentive Payment System (MIPS), clinicians can finally see the finish line approaching for the 2018 performance year. This year MIPS is made up of 4 components: Quality, Promoting Interoperability (formerly ACI), Improvement Activities and Cost. The Quality category accounts for the most at 50% of your total MIPS score. While many clinicians have already collected data throughout the year, it’s not too late to develop a strategy to successfully report Quality and potentially maximize your Medicare reimbursements in 2020.

CMS recently announced it made some changes to the 2017 MIPS performance feedback and is extending the deadline to request a targeted review until October 15, 2018, at 8:00pm (EST). Clinicians and groups are being encouraged to log into their CMS Enterprise Identity Management (EIDM) accounts on the Quality Payment Program (QPP) website to review their final MIPS scores and payment adjustment information for the 2017 performance year.

The minimum reporting requirements and penalties for not reporting under the Medicare Merit-based Incentive Payment System (MIPS) continue to steadily increase each year. Last year, MIPS eligible clinicians and groups could report just 1 patient to earn 3 MIPS points and avoid a 4% penalty in 2019. For 2018, providers must earn at least 15 MIPS points to prevent a 5% cut to their Medicare payments in 2020.

Fortunately, 15 points is still a low threshold and providers have a few different options to meet it.

Before you begin your 2018 MIPS reporting, the first step you should take is to determine if you are required to report this year by checking your participation status on the CMS website. The Quality Payment Program (QPP) Participation Status tool allows clinicians to view their status for each performance year for both the Merit-based Incentive Payment Program (MIPS) and the Alternative Payment Model (APM). Keep in mind if you are not exempt from MIPS participation in 2018, failing to report will result in a 5% penalty on your Medicare Part B payments in 2020.

Are you a solo practitioner or small practice struggling to understand MIPS requirements? When it comes to MIPS reporting, small practices face unique challenges that can make compliance seem like a daunting task. Choosing not to report could be a costly mistake, though, since the penalty for not reporting in 2018 has increased to 5% of your Medicare Part B reimbursements. Fortunately, CMS has taken several steps to provide relief to small practices so they can successfully participate in MIPS for the 2018 performance year.

Are you wondering how you performed in the 2017 MIPS program?  The wait is finally over. MIPS eligible clinicians and groups can now view their performance feedback for their 2017 MIPS submission on the CMS Quality Payment Program (QPP) website.  The performance feedback will include the clinician's or group’s final score and payment adjustment information.  Any upward, downward or neutral payment adjustment will apply to the provider's or group’s 2019 Medicare Part B payments for covered professional services.

Year 2 of the MIPS program, which runs from January 1, 2018, to December 31, 2018, will directly impact your Medicare Part B reimbursements in 2020. Understanding how CMS determines your final MIPS score will ensure your practice avoids any Medicare cuts, while giving you the opportunity to maximize your practice revenue.

CMS announced it exceeded its year one participation goal for the Quality Payment Program. According to CMS Administrator Seema Verma, 91% of eligible clinicians participated in the Merit-based Incentive Payment System (MIPS) in 2017. Submission rates for Accountable Care Organizations (ACOs) were 98% and rural practices were 94%.

CMS announced it will release MIPS Final Scores and Feedback for the 2017 Performance Year in July. Clinicians can view their preliminary performance feedback now on the Quality Payment Program website. However, the scores can change between now and July based on a few different factors.