MIPS regulations

What are the Proposed MIPS Changes in the 2019 Quality Payment Program?

When rules to the program you use to provide better care change, it’s frustrating trying to determine what they mean and how they’ll impact your ability to continue providing quality care for your patients. With the recent MIPS changes for the 2019 Quality Payment Program proposed rule, there has been a lot of confusion about how this will impact patient care. Here’s a quick rundown to help you get started in understanding how these changes will impact your practice.

Proposed MIPS Changes in the 2019 Quality Payment Program

The recent CMS release of a new proposed rule for Year 3 of the Quality Payment Program (QPP) includes several changes to the Merit-Based Incentive Payment System (MIPS). Focused on reducing administrative burdens for clinicians, the program should help transition providers to value-based care. The implementation period was extended to make it easier for providers to adapt.

CMS is accepting public comments and recommendations until September 10, but before you comment, it’s important to understand the broad strokes of the proposed changes:

  • More providers can participate as MIPS-eligible clinicians. The definition of MIPS-eligible clinicians will be expanded to include other types of clinicians such as occupational and physical therapists, clinical psychologists and clinical social workers. It’s also providing an exemption for clinicians who have 200 or less beneficiaries, 200 or less covered professional services and $90,000 or less in Part-B charges, though clinicians who meet one or two of the thresholds will have the option to participate in MIPS.
  • New policies will help reduce administrative burden. New episode-based measures will be added to MIPS’ Cost Performance category while the Advancing Care Information category will be renamed the Promoting Interoperability category. This will help support improvements in EHR interoperability by aligning the category closer to the Promoting Interoperability Program that applies to hospitals. The policies will also move clinicians to smaller objectives and measure set using scoring focused on performance and a combination of data collection types for Quality Performance category. This will allow clinicians to retain bonus points for scoring methodologies used in complex patient cases, small practices and end-to-end electronic reporting.
  • Additional flexibility will be retained for the small practice bonus. This allows the bonus to be used in the Quality Performance score of each clinician rather than counting it as a standalone bonus. It also provides for the awarding of three points for quality measures that are now in compliance with data completeness requirements for small practices, while identifying small practices through consolidation of low-volume threshold determination period.
  • Added terminology. Collection types will now include qualified clinical data registries (QCDR) measures, MIPS clinical quality measures, Medicare Part B claims measures, eCQMs, CMS web interface measures, CAHPS for MIPS survey measures, and administrative claims measures. Submitter types will include the MIPS eligible clinician, practice group, or third party intermediaries acting to submit data. Submission type is used for mechanisms by which data is submitted to CMS, including direct, log in and attest, Medicare Part B claims, log in and upload and CMS Web Interface are all appropriate submission types.


Where does your practice fall with these changes? Many clinicians and practices feel that the MIPS program isn’t doing enough to lighten the burden. If you need help determining how to adapt your current EHR system, Exscribe EHR can help. Please feel free to contact us today to get started in discovering where your practice can benefit from updated EHR interoperability today.