Top 5 Impacts Of The Final Rule

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Quality Program Services Coordinator

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The Centers for Medicare & Medicaid Services (CMS) issued the final rule listing changes for the third year of the Quality Payment Program as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In our last blog, we shared an in-depth explanation of the final rule, and what your practice needs to know about the changes for program year 3 of the Merit-based Incentive Payment System (MIPS). Read the full blog here.

In this blog, we are going to share TSI Healthcare’s top 5 impacts of the 2019 Final Rule.

  1. CMS expects payment adjustments to be larger than 2017
    • MIPS started in 2017 as the first performance year. Any payment adjustments for the 2019 performance year will be based on a 2-year look-back period. So, for example, if a provider earns a score above the performance threshold in 2019, he or she will receive a positive payment adjustment in 2021.
      • CMS predicts that these payment adjustments will increase, making the payment adjustment in 2021 higher than the one in 2017.

  1. The Promoting Interoperability (PI) Category will be more difficult
    • CMS requires 2015 Certified Electronic Health Record Technology (CEHRT) for the entirety of the 90-day PI reporting period in 2019.
    • For 2019, the base score has been removed. This means providers are now scored purely on performance.
      • Previously, eligible clinicians were given a base score of 50 points. However, now there is no more “head start”.  Failure to submit at least one beneficiary in the Numerator and Denominator for any measures results in a 0 for PI.
  1. The Cost Category changes & increases in weight (15%) while Quality Category decreases in weight (45%)
    • The new Cost measures may apply to your specialty, meaning you can no longer avoid being scored on Cost by staying below the thresholds on old Cost measures.
    • Practices will continue to be scored on traditional cost measures: Total per Capita Cost (TPCC) and Medicare Spending per Beneficiary (MSPB).
    • There are various ways to earn bonus points in Quality Category:
      • You may earn up to 10% of your total Quality score by submitting additional outcome and high priority measures beyond the one that is required.
      • End-To-End Reporting – You can earn up to 10% of your final Quality score in bonus points for submitting your measures in an end-to-end fashion, with no manual data manipulation.
  1. There will be more eligible clinician types and an additional eligibility criterion
    • ALL eligible clinician types from 2017 & 2018 will be eligible, along with the addition of the clinicians in the box to the right.

  1. Providers now have the option to opt-in to MIPS even if they do not meet all eligibility criteria.
    • Beginning in 2019, if providers meet at least one of the participation criteria, they are eligible to opt-in to MIPS at any point in the 2019 performance year and receive a payment adjustment.
    • Clinicians wishing to opt-in will make the election on the Quality Payment Program website. Please note that decisions to opt-in are binding and irreversible.

Want a quick run-down of MIPS Year 3? Download our MIPS Year 3 Final Rule guide. 

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Failure to meet regulatory requirements or failure to implement and utilize the necessary technology will impact eligibility, may result in missed incentives and/or penalties. TSI Healthcare (TSI) attempts to provide basic guidance of current policy, CMS guidelines, and NextGen documentation. TSI does not present findings or guidance as expert advice regarding federal policies, their requirements, data collection methods, or reporting guidelines. “Meaningful Use” requirements and other incentives programs are defined by the various agencies and offices of the US Federal Government and are subject to change. As guidelines change, NextGen’s approach and TSI’s guidance may also be adjusted without notice. TSI does not administer incentive payments, guarantee eligibility, or guarantee the accuracy of analysis and any statements about the program. TSI Healthcare and the NextGen® family of products and services can only provide the tools to achieve these requirements; however the responsibility remains on the provider to achieve, correctly collect data, maintain documentation, and report on each measurement. Should the Client have any questions as to the interpretation of ARRA, the HITECH Act or other relevant rules, regulation or incentive programs, and/or their application to the specific practice, the Client should contact the appropriate government agency directly.

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