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MIPS 2019: What You Need to Know

Wednesday, December 5, 2018 9:00 AM

Hot Topics, Billing, Coding & Compliance

Written by: Elizabeth Cifers, Laurie Brown

Laurie Brown
Senior Consultant
Elizabeth Cifers
Former Senior Consultant

The end of 2018 marks the second calendar year since the Merit-based Incentive Payment System (MIPS) was integrated into ophthalmology practices across the country. Hopefully, you successfully avoided penalties and perhaps even received some level of bonus. Looking ahead to 2019, abiding by MIPS may prove more challenging, as practices will be required to begin using the 2015 version of the certified electronic health record technology (CEHRT) software.

Upcoming Changes

When dealing with an ever-evolving program such as MIPS, the best way to ensure compliance is to stay well-versed on any changes going into effect each year. To help your practice be successful in 2019, we’ve highlighted some areas that will be updated. They include:

Penalty avoidance performance threshold. This threshold is changing from 15 points to 30 points in 2019. It should be achievable for most ophthalmic practices.

Exceptional performance bonus threshold. This threshold for composite scores is changing from 70 points to 75 points. Additional bonus points will still be available to small practices and/or practices with complex patients. These bonuses are automatically applied.

Cost factor. Starting in 2019, the cost factor will increase to 15 percent of MIPS scoring. Unfortunately, ophthalmologists have little to no control over this category.

Advancing Care Information (ACI). This category’s name was changed to Promoting Interoperability.

Promoting Interoperability scoring. The scoring will be slightly more user-friendly in 2019. However, there are still minimum measures that must be met to ensure credit for this category.

Quality and Improvement. When reporting your activity data in 2019, you will still be able to use either 2014 or 2015 CEHRT software. However, you must transition to the 2015 version this coming year to report the Promoting Interoperability category, so it’s important that you make the upgrade as soon as possible.

Reimbursement effect. The penalty for underperformance will increase to 7 percent for 2019, as is the upside positive payment adjustment potential.

Removal of three quality measures. The three quality measures (which are used by ophthalmology) that were removed are:

  • Measure 18 – Diabetic Retinopathy Documentation of Macular Edema and Severity of Diabetic Retinopathy,
  • Measure 140 – AMD Counseling on Anti-Oxidant Supplements, and
  • Measure 224 – Melanoma Overutilization of Imaging Studies. 

Staying the Same

While each new year brings changes to the MIPS program, some aspects will remain the same. They include:

Improvement Activities. Small practices (less than 15 eligible clinicians) will continue to receive full credit in this category by successfully submitting one high-weighted measure.

Quality reporting. This must still be reported for a full 12 months without a 90-day option. The Improvement Activities (IA) and Promoting Interoperability (PI) measures can be reported for either any 90-day period during the year or the full year; the choice is yours.

Quality bonus scoring. There will be bonus scoring of the Quality category applied again in 2019, related to improvement over past reporting (without penalty for underscoring compared to past performance).

Individual and group reporting. There will still be the option to report as individuals or groups, as well as the virtual group option. If you plan to use the virtual group designation, it needs to be declared to the Centers for Medicare and Medicaid Services (CMS) by Dec. 31, 2018. Group reporting still appears to be advantageous for most ophthalmology practices.

Audits. These are continuing, so it’s recommended you retain documents for six years in case you are audited.

Targeted review of MIPS scores. This option, which was new last year, will continue in 2019. You can apply for a review of your 2018 MIPS score, if you disagree with it, post score publication next summer. The published deadline is Sept. 30, 2019.

AAO’s IRIS Registry

While there are a few platforms that offer MIPS program support, the American Academy of Ophthalmology (AAO)’s Intelligent Research in Sight (IRIS) Registry remains the preferred platform for most ophthalmic practices. Not only did IRIS greatly increase its ability to report quality measures in 2018, but it also continues to participate in testing measures to set threshold scores. Using these newer qualified clinical data registries (QCDR) measures for testing may earn you additional points. Perhaps most valuable, the IRIS Registry will, at the time of attestation, review your performance across all quality measures to submit the most advantageous score for you or your group. To learn more about why ophthalmic practices prefer the IRIS Registry, read our 2018 MIPS blog post.

Do the Best You Can

After two years of implementation, MIPS has become more manageable, and we encourage participation. Similar to last year, our advice to clients is to participate with your best effort while staying aligned with your practice’s focus and activities. Generating sensible reporting should be just another operational practice — one that easily integrates into your mission to always do the best you can for your practice.

MORE ONLINE: Learn more about MIPS at


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