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On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released its 2019 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) final rule. In response to the ASRS and other organizations' comment letters and intensive lobbying efforts, CMS final policy only applies to the MIPS payment adjustments to covered professional services and?not Part B drugs.MIPS ExclusionsPhysicians and groups fall under the low-volume threshold and are exempt from MIPS if they:Bill $90,000 or less in Medicare Part B allowed charges for covered professional services payable under the MPFS, orProvide covered professional services for 200 or fewer Part B-enrolled individuals, orProvide 200 or fewer covered professional services to Part B-enrolled individualsIf you're exempt from MIPS for Performance Year 2019, you can choose to opt-in to MIPS if you exceed 1 or 2 of the above criteria and receive a MIPS final score and a payment adjustment in 2021. If you are not exempt and choose not to participate in 2019, you will receive a negative 7% payment adjustment in 2021. This penalty will increase to negative 9% by 2022.?ASRS urges you to participate. Physicians who score 30 out of 100 total points will avoid the 7% penalty. Those with final scores above this “performance threshold” of 30 points may receive positive payment adjustments. Overview of MIPSPerformance Categories/Weight Contributing to Total ScoreCMS rates MIPS participants in four performance categories: Quality; Cost; Promoting Interoperability (formerly Advancing Care Information); and Improvement Activities. CMS finalized the following weights for each of these categories in 2019:Quality – 45% (50% in 2018)Cost – 15% (10% in 2018)Promoting Interoperability – 25%Improvement Activities – 15%* If no patient costs are attributed in 2019, 15% will be added to the weight of the Quality performance category. ?Performance PeriodsQuality and Cost categories remain 1 full year (January 1 - December 31, 2019). Promoting Interoperability (PI) and Improvement Activity categories remain any continuous 90-day period or longer - up to the full year. Bonus PointsSmall practices (15 or fewer eligible clinicians) that submit quality measures for 2019 receive a bonus of 6 points to the Quality category score, not the final MIPS score. Complex Patient Bonus – remains at up to 5 points added to final score based on the medical complexity of patients treated. MIPS performance data for 2019 must be submitted by March 31, 2020.MIPS Scoring Details for CY 2019The payment adjustment for 2021 (based on 2019 performance) will range from -7% to +7%, plus any scaling to achieve budget neutrality, as required by law. Payment adjustments will apply to professional services paid under the Medicare physician fee schedule (PFS), excluding Part B drugs.The threshold score required to receive a neutral (no penalty) or positive payment adjustment increased from 15 points in 2018 to 30 points in 2019. A score below 30 will result in a negative payment adjustment.Physicians who achieve a final score of 75 or higher will be eligible for an exceptional performance adjustment, funded from a pool of $500 million, applied on a linear scale so that higher scores receive a higher adjustment (from 0.5 to 10 percent).QualityParticipants have the same requirement to report on at least 6 measures or a complete specialty measure set; one measure must be an outcome measure or, if none are applicable, a high priority measure. If fewer than six measures apply, report on each measure that is applicable. Individuals or groups can submit any combination of measures across collection types (electronic Clinical Quality Measures (eCQMs), MIPS CQMs (formerly "Registry measures"), Qualified Clinical Data Registry (QCDR) Measures, and Medicare Part B claims measures (only small practices)). The most recent version of the eCQM must be used.Retina specialists have 16 relevant measures to report in 2019, two that were available in 2018 have been removed: Measure 18: Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of RetinopathyMeasure 140: AMD: Counselling on Antioxidant SupplementPhysicians still earn up to 10 points for each Quality measure reported. The data completeness reporting threshold remains 60 percent of all patients (or 60% of Part B patients for claims measures), with a minimum of 20 cases per measure. If a measure has a benchmark and a physician meets the data completeness criteria, they receive 3-10 points based on performance compared to the benchmark. If a physician fails to meet the data completeness criteria in 2019, they receive 1 point but will receive 0 points in 2020 (small practices will continue to receive 3 points in both performance years).Performance improvement remains the same. Up to 10 points may be added for improvement based on percentage changes from year to year. Because physicians may report different Quality measures from year to year, improvement is not measure-specific but based on the entire category. Any improvement in 2019 compared to 2018 is added into the overall Quality score. CMS will assign a Quality category score of 30 for physicians who scored less than 30 in 2018 for comparison with 2019. Thus, improvement scoring will not reduce, but only add to the overall quality score. Quality Bonus Points:2 bonus points for each outcome and patient experience measure and 1 bonus point for each other high priority measure (bonus awarded for the second outcome or high priority measure not submitted via CMS Web Interface). Capped at 10 percent of the total available measure achievement points.1 bonus point (capped at 10) for each quality measure submitted using End-to-End Electronic Reporting (submitted by direct, log in and upload or CMS Web Interface ) from a 2015 edition certified EHR technology (CEHRT) 6 bonus points added to the Quality performance category score for physicians in small practices who submit at least one measure, either individually or as a group“Topped Out” MeasuresCMS will maintain its 4-year cycle for removing measures considered “topped out” (performance is so high and unvarying that meaningful measurement of change or improvement can no longer be achieved). In 2019, measures identified as “topped out” for two consecutive years will receive a maximum of 7 points in the second year. New: Extremely topped-out measures (e.g., a measure with an average mean performance between the 98th to 100th percentiles) will be proposed for removal in the next rule-making lifecycle. QCDR measures are excluded from the topped-out measure life cycle.CostCMS finalized 8 new episode-based cost measures, although none apply to retina specialists. Cost measures for retina specialists will continue to be the Medicare Spending Per Beneficiary (MSPB) and total per capita cost for all attributed beneficiaries (TPCC) measures. If you are not attributed costs for any patients, the category will be reweighted to the Quality category.Performance improvement scores for all physicians remain at zero for 2019. Congress retroactively delayed implementation of improvement scoring in the Cost category until the 2022 performance year. Promoting Interoperability CMS revamped this category, eliminating the “base, performance, and bonus score” structure. Physicians must report measures under four objectives that focus on patient care and interoperability of health data exchange with varying maximum points, up to a potential score of 100, unless an exemption applies. (See chart below) In addition to submitting measures, you must:Submit a “yes” to the Prevention of Information Blocking Attestation,Submit a “yes” to the ONC Direct Review Attestation; andSubmit a “yes” for the security risk analysis measurePromoting Interoperability 2019 Scoring ObjectivesMeasuresMaximum Pointse-Prescribinge-prescribing 10 points Bonus: Query of Prescription Drug Monitoring Program5 bonus points Bonus: Verify Opioid Treatment Agreement5 bonus points Health Information ExchangeSupport Electronic Referral Loops - SendingHealth Information20 points Support Electronic Referral Loops - Receiving and Incorporating Health Information20 points Provider to Patient ExchangeProvide Patients Electronic Access to Their Health Information40 pointsPublic Health and Clinical Data ExchangeChoose two: Immunization Registry Reporting Electronic Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting Syndromic Surveillance Reporting10 points2015 Edition CEHRT is required in 2019 and there is no longer a bonus for using it. Physicians who lack access to 2015 Edition CEHRT (e.g., their EHR vendor does not make 2015 Edition EHR available in time to meet the requirements of the category) will be able to request a hardship exception. Bonus Points5 bonus points each may be earned for reporting 2 optional measures in 2019: Opioid Treatment Agreement and Query of PDMP.Hardship Exceptions (CMS will reweight the PI category to the Quality category if approved)MIPS eligible clinician in a small practiceMIPS eligible clinician using decertified EHR technologyInsufficient Internet connectivityExtreme and uncontrollable circumstancesLack of control over the availability of CEHRTImprovement ActivitiesCMS retained medium and high weighted activities, adding 6 new activities, modifying 5 existing activities and removing 1 activity. In 2019 CMS will continue to permit a group to receive credit for animprovement activity completed by one physician and reporting is still based on attestation. CMS discontinued bonus points for completing certain improvement activities using a CEHRT.How will your 2019 MIPS participation choices impact your 2021 payment adjustment?Additional ResourcesQuality Payment Program Resource LibraryA Quick Start Guide to the Merit-Based Incentive Payment System (MIPS) for 2019 Participation AAO provides MIPS Quality Measures for Retina ................
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