There are three changes to the 2019 Quality Payment Program from the 2019 Final Rule that could surprise and severely impact a practice if they are unaware.

1) Claims-based Submissions: Only small practices of 15 or fewer clinicians can submit Quality Data Codes and earn credit for MIPS.

Claims-based reporting has been the most popular form of CMS Medicare Quality reporting since the days of PQRS. This method requires affixing a Quality Data Code (QDC) to each claim with an eligible patient that has had the quality action required for a measure. QCDs are also called G-codes and CPT II codes. The method is fraught with opportunity for missing a claim or choosing the wrong QDC code. CMS has talked about phasing it out for the past several years. In prior years, CMS had reduced the number of Claims-based measures but otherwise has not followed through on their intention to eliminate claims-based reporting. Finally, in the rules for the 2019 Quality Payment Program, we see evidence that CMS is following through on their intentions.

That doesn’t mean that using QDCs aren’t a useful way to collect MIPS numerator data. Most measure specifications include QDC codes that can be used to collect performance. Those codes can then be repurposed and used to make a Registry submission.

However, If a medium to large-sized practice continues to use Claims Codes but does not work with a Registry to use them to make a Registry submission, CMS will award zero points in the Quality category.

2) 2015 CEHRT: You must use 2015 CEHRT to report any measures in the Promoting Interoperability Category.

The PI category evolved from the original EHR incentive program and former Advancing Care Information category under MIPS. These programs were intended to gradually and consistently move practices toward more meaningful use of their EHR and included measures that reflected the ability of EHRs to exchange information. With the change of the name to Promoting Interoperability, CMS has declared its intention to move practices toward the next level of information exchange. The measures have been revamped to reflect the emphasis. The 2015 CERHT gives additional capabilities to exchange information via an Application Programming Interface (API) that is thought to accelerate information exchange.

Without 2015 CEHRT, you cannot earn ANY points in the Promoting Interoperability category.

3) MIPS Eligibility: New specialties are now considered MIPS Eligible Clinicians

Several specialties that were included in PQRS were exempt for MIPS for the first two years. Now most specialties that were excluded, are back in the program and subject to penalty for not reporting.

• Physical therapist
• Occupational therapist
• Qualified speech-language pathologist
• Qualified audiologist
• Clinical psychologist
• Registered dietitian or nutrition professionals

If you want to protect your income and your bottom line, keep these three changes in mind as you start planning your 2019 MIPS submission. Don’t forget, our friendly Consultants are standing by to help assist you with your quality reporting needs – contact them today for additional guidance and MIPS submission support.

Want a more in-depth look at the 2019 Final Rule? Watch Dr. Dan Mingle’s webinar, 2019 Final Rule: MIPS and the Quality Payment Program, on demand now for a concise overview.

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