MIPS for Pathologists: Proposed changes for 2020

July 31, 2019

Just as participants of the Merit-based Incentive Payment System were becoming comfortable with the programs requirements and the steps necessary to avoid penalties to their Medicare Part B payments, CMS has indicated it intends to again ramp up reporting requirements for the 2020 performance year, according to the 2020 Medicare Physician Fee Schedule Proposed Rule published July 29.

As with past year’s, 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 proposed baseline performance threshold of 45 points is set to rise to -9%. 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 initial clarification on the existing Pathology Specialty Measure Set, which has undergone persistent revisions in recent years as the already limited set had multiple “topped out” measures retired. Here is a quick rundown of the major proposals that could be finalized when the 2020 MPFS Final Rule is released:

  • Higher points threshold to avoid a penalty: In the rule, CMS signaled its intent to increase the penalty avoidance threshold to 45 points, up from the 30-point threshold for 2019 reporting. If passed this will be a significant step up from the original 3-point transition threshold that kicked off the program in 2017. However, this change should be expected to pass as it’s in line with CMS’s longstanding goal of continuing to raise the performance threshold as providers become more comfortable with the program’s reporting requirements.
  • Existing pathology quality measures expected to remain in place: After retiring three “topped out” measures from the Pathology Specialty Measure Set for 2019 reporting, there was concern that CMS may retire additional pathology measures for 2020 as well. However, 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), they agency also said it believes it’s important to maintain these measures in order to provide pathologists with reporting options. Additionally, participants are expected to continue to have access to the additional pathology-specific QCDR measures available exclusively through the College of American Pathologists Pathologists Quality Registry.
  • Increased weight for Cost category: While the cost category still won’t require manual reporting and will only apply to those who meet the minimum case volume necessary to be scored, CMS has proposed to raise the weight of this category from 15% to 20% of a participant or group’s overall score. Those who don’t meet the case volume necessary to be scored on applicable cost measures will continue to see the category reweighted to affect their Quality score.
  • Increased data reporting requirement: Finally, CMS is proposing to increase the data threshold for quality measures to 70% of a participant’s applicable cases, up from the 60% threshold of 2019. Failing to meet the new threshold for a quality measure will result in a score of “0” unless the participant is part of a small group.

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