MIPS 2019: Commenting on the Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) released the Proposed Rule for 2019 and practices are encouraged to comment on the changes here. Although the Proposed Rule states that all comments must be submitted by 5 p.m., Sept. 10, 2018, comments submitted electronically to www.regulations.gov will be accepted until 11:59 p.m. ET.

Practices are strongly encouraged to make their comments known as many of the changes will have a significant impact to practice operations. The entire Proposed Rule can be downloaded at the PDF icon on the above link to the CMS comment page.

The top things to consider under the 2019 Proposed Rule include:

In the Promoting Interoperability category (formerly known as Advancing Care Information, and in prior years, Meaningful Use), CMS has proposed to significantly reduce the number of available measures for reporting. Currently practices must earn 100 out of the total 165 available points to achieve the full Composite Score of 25 points for this category.

In 2019, practices will have to earn 100 points out of only 110 points available to earn the full score. This includes two bonus measures worth five points each, if you are able to report on the new measures and if EPCS is allowed in your state. Starting in 2020, these two measures are proposed to be required and providers will have to earn 100 out of 100 total possible points to achieve the full score for this category.

In the Quality category, CMS is adding 10 new measures (examples: HIV Screening; Zoster/ Shingles Vaccination: etc.), but looking to remove 15 other measures (examples: Falls: Risk Assessment; Fall: Plan of Care; Oncology: Radiation Dose Limits to Normal Tissues; etc.) The measures proposed for inclusion, removal and modifications can be found in Table Group A through D in the Proposed Rule.

Practices should take the time to review the list of Quality Measures. There may be some measures that your practice is collecting data for that could be discontinued the following year.

CMS has stated in calls and webinars that they are looking for input from providers and practices.

If you have additional questions about the 2019 Proposed Rule or questions about MIPS reporting, the Quality Reporting Engagement Group will be able to assist you. 

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