When QPP began on January 1, 2017, it brought significant change to the way providers were reimbursed for services provided to Medicare patients. In the past, the emphasis was on the number of services provided to a patient via fee-for-service. That meant that providers benefited from the number of services for the patients they treated, regardless of effectiveness. The quality of their services was not evaluated, which shortchanged many conscientious, skilled physicians, clinics, and hospitals. 2020 QPP changed that practice by enforcing quality standards that determine the level of reimbursement providers receive. Better care equals more money. Such a major change caused providers to scramble to meet the new rules. Many well-meaning providers have struggled to master QPP during this transition.
Keeping up with QPP rules is a challenge for the most proactive healthcare providers. Just as you managed to adjust to the 2019 changes, the 2020 QPP modifications were announced. CMS has made it its mission to raise MIPS participation rates and respond to the concerns of providers. As a result, they are slowly making changes to QPP to reduce participation difficulties for participants. At the same time, they strive to ensure that the quality of patient care continues to improve. The new rules require that you make further adjustments to your patient care and financial expectations, but some of these policies will be in your favor.
2020 QPP MIPS Changes
Several QPP rule changes have been finalized, while others are proposed for 2021 and beyond. The major MIPS rules for the 2020 performance year are as follows:
As anticipated, the Merit-based Incentive Payment System (MIPS) is raising the performance threshold points from 30 in 2019 to 45 in 2020. This significant jump will make avoiding a negative payment adjustment more difficult, which has serious financial implications for some providers. However, the score will serve to increase patient protections. Other 2020 performance thresholds and category weights include the following:
The exceptional performance threshold will be raised to 85 points.
The Quality performance category stays weighted at 45%.
The Cost performance category remains weighted at 15%.
The Promoting Interoperability performance category remains weighted at 25%.
The Improvement Activities performance category remains weighted at 15%.
Several of these categories remained steady but may be adjusted in the upcoming years.
Quality Performance Category
Some important adjustments have been made in this category as well. The 2020 program includes the following updates to quality performance categories:
The data completeness threshold is going from 60% to 70%. Those who fall below this threshold will receive 0 points unless they are a small practice. In that instance, they will earn 3 points.
CMS is adding new specialty sets such as Speech-Language Pathology, audiology, Nutrition/Dietitian, etc.
Officials are also continuing to apply their Meaningful Measures framework to remove the lower standard of care and process measures from the QPP.
Cost Performance Category
The QPP is adding 10 new episode-based measures so that more providers will qualify for this category. Also, they are revising the Medicare Spending Per Beneficiary Clinician and Total Per Capita Cost measures.
Changes to the Quality and Cost performance category weights were proposed and have not been finalized. They could be part of the 2021 changes instead.
Improvement Activities Performance Category
CMS is making it easier to receive a patient-center medical home (PCMH) designation. They are also increasing the participation threshold for group reporting, meaning that now 50% of the clinicians in a practice must perform the same improvement activity instead of being allowed to rely on a single clinician's efforts. The Improvement Activity Inventory is also being updated.
Promoting Interoperability Performance Category
The Query of Prescription Drug Monitoring Program, or PDMP, is now an optional measure that can give providers bonus points. Other changes to this category include:
Removal of the Verify Opioid Treatment Agreement measure.
They are reducing the threshold for hospital-based groups from 100% of clinicians to more than 75% of group clinicians. This means that fewer providers must be a hospital-based individual MIPS eligible clinician for the group to be excluded from the Promoting Interoperability performance category.
In Performance Year 2019, they are redistributing the points for the Support Electronic Referral Loops by Sending Health Information measure to Provide Patients Electronic Access to their Health Information measure.
Also, CMS is working to strengthen relationships with third-party intermediaries and further simplify the reporting process. As a result, they require Qualified Clinical Data Registries and Qualified Registries to comply with MIPS performance categories that require certain data be submitted and to offer feedback to clinicians so that they can compare their performance to other providers in the registry.
2020 QPP Advanced Alternative Payment Models Changes
Those who are enrolled in Advanced Alternative Payment Models (APM) will also have to deal with changes to 2020 QPP in Year 4. Currently, the main alterations to the APMs are as follows:
APM Entities and MIPS eligible clinicians who participate in APMs have the option to report on MIPS quality measures for the MIPS Quality Performance category - this stipulation applies when quality scoring through MIPS is not already a requirement of the APM. This change means APM Entities will get a calculated score based on individual, TIN, or APM Entity reporting.
Some APM entities participating in MIPS will have a minimum score of 50%, or an APM Quality Reporting Credit, applied when APM quality data are not being used for MIPS reasons. They can submit their quality measures to MIPS, and the score will be added to their credit. The credit is capped at 100.
For those in APM, the 2020 changes should be easier to navigate than those in MIPS.
The certified electronic health record technology, CEHRT, requirements remain the same. Those providers who are changing to a new EHR system during a performance year need to acquire a full report from the first EHR so that they can submit the required 12 months of data to QPP. Failure to have full reports from both EHR systems may lead to problems with reimbursements.
Eligibility standards for MIPS in 2020 remain the same. You must be an eligible clinician type, exceed the low-volume threshold, and not be excluded due to your Medicare enrollment date or as a Qualifying APM Participant.
The maximum negative payment adjustment is now set at -9% and will be put into effect during the 2022 payment year and determined by the 2020 performance year. The point system includes these adjustments:
0.00 - 11.25 points - -9% payment adjustment
11.26 - 44.99 - Negative payment adjustment between -9%and 0
45.01 -84.99 points - Positive payment adjustment
85.00- 100.00 points - Positive payment adjustment
The changes are a mixed bag for providers, with some scoring procedures requiring a higher level of performance than in the past to avoid negative payment adjustments. In addition to the finalized changes, CMS has proposed a number of other alterations that have yet to be finalized. However, these proposals certainly suggest that 2021 will bring additional changes to performance, quality, and cost rules.
Proposed 2021 QPP Change
The executive committee has already proposed a rule change for 2021 that will create a new MVP (MIPS Value Pathway). The purpose of the rule is to simplify the system for providers while providing patients with more information to help them choose the best healthcare providers for their needs. This proposal and others are already on the table for 2021 and beyond, so keeping up with QPP will not be easier in the upcoming years.
Remaining up-to-date on QPP is a challenge for any provider. That's why you may need the assistance of TempDev to assist you with your readiness assessment, preparation, and data submissions.
QPP is always going to be a work in progress. Meeting the needs of Medicare providers and patients is a delicate balance that requires frequent rule changes and careful monitoring by the government. Any provider is going to find keeping up difficult. However, submitting the wrong information or failing to meet new expectations can cost you an enormous amount of money and harm your reputation. That's why you need the help of QPP experts such as you'll find at TempDev.
QPP regulations are often confusing, and you can easily make reporting mistakes if you are not a quality specialist. TempDev's expert staff has an in-depth understanding of the QPP's origins and its continuous changes. They know how the rules have evolved and what they are at the moment. They make sure that you submit your data accurately the first time, which speeds up the reimbursement process, preventing financial shortfalls. They also know what additional changes are on the horizon, so they can help you prepare for next year's APP rules.
At TempDev, they stay current with the latest breakthroughs in the medical industry, including the newest information about NextGen and assisting with using NextGen EHR & NextGen HQM. They understand the challenges facing healthcare providers. Don't struggle with QPP on your own this year. Instead, contact the experts at TempDev to assist you through the process.
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