2019 MPFS proposed rule: QPP proposals eliminate low-priority process measures, promote interoperability

July 23, 2018

The 2019 Medicare Physician Fee Schedule (MPFS) proposed rule includes updates to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS) which impact 2019 provider eligibility and MIPS category weights.

Changes to the QPP will affect providers enrolled in either MIPS or an Advanced Alternative Payment Model (Advanced APM). Documentation submitted for calendar year (CY) 2019 will have a payment impact in 2021.

For year three of the program, CMS proposes to overhaul the Promoting Interoperability performance category to support greater EHR interoperability and patient access. The Promoting Interoperability performance category would be modified to align with the proposed Promoting Interoperability Program requirements for hospitals.

The proposed rule would expand the definition of a MIPS-eligible clinician to include physical therapists, occupational therapists, clinical social workers, and clinical psychologists.

In addition, the proposal increases the weight for the cost performance category from 10% to 15%. For MIPS-eligible clinicians, the proposed CY 2019 weights are:

  • Cost: 15%
  • Improvement Activities: 15%
  • Promoting Interoperability: 25%
  • Quality: 45%

Other prominent QPP proposals include:

  • Adding a third element to the low-volume threshold determination, which will give eligible clinicians who meet one or two elements of the low-volume threshold the choice to participate in MIPS.
  • Adding flexibilities for physicians in small practices. CMS proposes to continue the small practice bonus and to include the bonus in the Quality performance category. It also proposes to award small practices three points for quality measures that don’t meet the data completeness requirements.
  • Maintaining the low-volume threshold for MIPS exemption at $90,000 or less in Part B allowed charges or 200 or fewer Medicare beneficiaries.
  • Removing MIPS process-based quality measures that the agency has deemed low-value or low-priority to focus on measures that may have a greater impact on health outcomes.   

CMS released a fact sheet detailing these and other proposed changes for year three of the QPP.

The proposed rule will be published in the Federal Register on July 27. Comments can be submitted to CMS until September 10.