MIPS for Pathologists: Finalized changes for 2020

November 5, 2019

Just as participants of the Merit-based Incentive Payment System were becoming comfortable with the program’s requirements and the steps necessary to avoid penalties to their Medicare Part B payments, CMS has indicated it will again ramp up reporting requirements for the 2020 performance year, according to the 2020 Medicare Physician Fee Schedule Final Rule published November 1.

As with past years, there is a two-year gap between the performance and corresponding payment year, which means 2020 performance will impact payments received in 2022. However, the penalty for failing to achieve the finalized baseline performance threshold of 45 points is set to rise to -9%, a significant increase from the 3% penalty for poor performance when the program was first introduced.

When considering the upside for bonus payments for exceeding the performance threshold, it becomes clear that the 2020 MIPS performance year is when CMS expects to separate those who truly embrace MIPS from groups just doing the bare minimum to get by. Additionally, CMS also provided some clarification on the existing Pathology Specialty Measure Set, which has undergone persistent revisions in recent years as the already limited set had three “topped out” measures first introduced for PQRS retired.

Here is a quick rundown of the major proposals that were finalized in the 2020 MPFS Final Rule:

Higher point threshold to avoid a penalty: In the rule, CMS increased to the penalty-avoidance scoring threshold to 45 points, up from the 30-point threshold for 2019 reporting. And don’t get too comfortable with the new goal, either. While still a ways off, the rule also locked in the 2021 performance threshold at a whopping 60 points. The training wheels are coming off, folks!

Data reporting threshold for quality rises: CMS has increased the data completeness threshold for quality measures to 70% of a participant’s applicable cases, up from the 60% threshold of 2019.

Existing pathology quality measures to remain in place, one added: Despite CMS admitting in the rule that four of the five existing measures are “extremely topped out” (translation: participants score so well on these measures there is little room for variance in scoring), the agency also said it believes it’s important to maintain these measures in order to provide pathologists with reporting options. Measure Q440 (Basal Cell Carcinoma/Squamous Cell Carcinoma: Biopsy Reporting Time – Pathologist to Clinician) has also been added to the pathology specialty measure set, giving the set six total measures for 2020.

Category weighting to remain in place: Participants will again see Quality comprise 45% of their overall score, with Promoting Interoperability consisting of 25% and Cost and Improvement Activities each totaling 15%. However, most pathologists and non-patient facing groups will continue to be exempt from the PI category and will most likely not meet case volume requirements to be scored for Cost. In the event of these exemptions, the category weights are redistributed to the Quality total, meaning the vast majority of pathologists will continue to see Quality comprise 85% of their overall score.

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