mechanism in 2019. Formerly, this was limited to clinicians reporting as individuals. CMS is also maturing the process whereby
quality measures that traditionally have very high performance
(i.e., “topped-out” measures) are being removed. CMS added 10
new quality measures and removed a total of 26 topped-out and
otherwise “non-clinically useful” measures in 2019.
MIPS Improvement Activities Performance
Category in 2019
There were minimal changes made to the improvement activities
category for 2019. Six new improvement activities were added,
five were modified, and one was removed. As noted previously,
the five percent Promoting Interoperability bonus associated
with the use of certain improvement activities has been removed.
MIPS Reporting Options for Facility-based Clinicians
Clinicians that are facility-based can use their hospital’s performance under the Hospital Value-Based Purchasing (VBP)
Program for the MIPS quality and cost performance categories. Facility-based clinicians are defined as clinicians that furnish 75 percent or more of their covered professional services
in inpatient hospitals, on-campus outpatient hospitals, or
emergency rooms. For groups, 75 percent or more of the clinicians in the group need to meet this same individual clinician
Facility-based practices retain the option of submitting quality
category performance data based on the MIPS quality category
performance. If the practice submits MIPS quality data, CMS
will use the higher of the two performance scores for the quality and cost categories (i.e., VBP vs. MIPS) as the performance
score for the quality and cost categories. The practice will need
to attest to meet the requirements for improvement activities.
Depending on exclusion status the practice may also need to report Promoting Interoperability performance data.
MIPS Bonuses in 2019
CMS has discontinued the five percent small practice bonus that
is applied to the total MIPS score in 2019. Small practices ( 15 and
fewer clinicians) will instead receive a six-point bonus added to
their quality scores. As noted above, CMS also removed bonuses
in the Promoting Interoperability category for specified improvement activities that involved the use of certified EHR technology.
Bonuses that CMS retained include the complex patient care
bonus (up to five points added to the total MIPS score) and bonuses associated with reporting additional outcome, high priority, and end-to-end electronic quality measures.
Advanced Alternative Payment Models in 2019
There were relatively few changes to Advanced APM requirements
for 2019. A brief overview of selected changes is provided below.
Qualified Participant (QP) Thresholds in 2019
As per statute the percentage of payments and patient volume
thresholds to achieve QP and Partial QP status increased for
the 2019 performance year (see Table 5 and Table 6 on page
32). This has been partially offset by the approval of the All-
Payer Combination and Other Payer Advanced APMs in 2019.
These initiatives will allow clinicians participating in non-QPP
Advanced APMs that meet CMS approval to have their pay-
ment and volume thresholds summated with QPP Advanced
APMs. This will allow larger numbers of clinicians to meet the
increased thresholds in 2019 and future years. Other APMs may
be Medicaid, Medicare Advantage, and CMS multi-payer mod-
els or commercial/private payer Advanced APMs.
A significant number of MIPS-eligible clinicians that met the
thresholds for partial QP status in 2017 and 2018 may find themselves not meeting the new threshold requirements in 2019. When
this occurs clinicians will receive a MIPS score that is not determined by the MIPS APM scoring standard (i.e., it will be based on
their or their group’s performance in the four MIPS categories).
MIPS-eligible clinicians with historical APM payment percentages
in the range of 20 percent and 40 percent and APM patient volumes
in the range of 10 percent and 25 percent may wish to consider having a MIPS performance strategy in place for 2019 and future years.
Certified Electronic Health Records Technology (CEHRT) Usage
Advanced APMs must require that at least 75 percent of eligible
clinicians in each APM entity are using CEHRT in 2019.
More Information Available in the Final Rule
This article provides an overview of changes to the Quality Payment Program in 2019. Please see the QPP section of the 2019
Physician Fee Schedule Final Rule and emerging guidance from
CMS for additional information. Additional information from
this author pertaining to the 2018 QPP performance year is also
available, published in an article in the February 2018 issue of
Journal of AHIMA. 6 ¢
1. Centers for Medicare and Medicaid Services. “83 FR 59452
(2019 Medicare Physician Fee Schedule Final Rule).”
Federal Register. November 23, 2018. www.federalregister.gov/
6. Marron-Stearns, Michael. “MACRA Strategies for 2018
and 2019 (Update).” Journal of AHIMA 89, no. 2 (February
2018): 22-27. http://bok.ahima.org/doc?oid=302408.
Marron-Stearns, Michael. “MACRA/Quality Payment Program in
2019: Finalized Changes.” Journal of AHIMA website. December
6, 2018. http://journal.ahima.org/2018/12/06/macra-quality-
Michael Marron-Stearns ( Michael@apollohit.com) is the CEO and founder of Apollo HI T, LLC.
MACRA 2019 Update:
What to Know