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An abundance of federal legislation has prompted several significant changes to the Quality Payment Program, Merit-based Incentive Payment System (MIPS), for the 2019 and 2020 performance years. CMS announced these changes in an attempt to grant some relief to the healthcare providers participating in the program.

At the start of May, program relief in 2020 centers around hospital quality reporting programs. CMS has stated they are evaluating options for providing relief around the participation and data submission for the 2020 MIPS performance year. It is essential that practices continue to collect MIPS quality data and plan accordingly until further insight from CMS is shared.

New in 2020

Also important to note, is a change that impacts those reporting as a practice. In years past, only one clinician from a practice would have needed to complete the activity for the entire practice to receive credit. Now, if you are reporting as a practice, 50% of the eligible clinicians must perform the same Improvement Activity for any continuous 90-day period during the performance year. This update poses a big logistical change, and practices should begin reviewing and discussing a strategy on how to complete this task for 2020.

Avoid a 9% Penalty

Remember, the minimum final score to avoid a penalty is 45 points.

  • Most groups will need to report on all applicable measures AND complete improvement activities to ensure a final score of at least 45 points.

  • The penalty for NOT reaching the score is up to 9% of 2022 Medicare Reimbursements.

Quick Refresher on Quality and Improvement Activity

The two most important MIPS categories for anesthesia practices are Quality and Improvement Activity. Here’s a quick refresher:

Quality Category (45% or more of the final score for most anesthesia practices)

  • Must report at least six individual quality measures

    • One must be an outcome measure OR a high-priority measure (the anesthesia measure set includes both)

    • If less than six measures apply, you MUST report on all applicable measures

  • Must report on 70% of the eligible cases for each reported measure for the performance to be included in the quality score calculation

The MIPS approved measure set remains mostly unchanged from last year; however, a new measure regarding multi-modal pain management was added.

Improvement Activity (15% of the final score)

  • Must report over 100 approved improvement activities for 2020

  • Web-based attestation is available for providers and practices

  • Each activity is assigned a weight; Medium = 10 points and High = 20 points

  • Must obtain 40 points to get full credit towards the final score

Many anesthesia practices, however, fall into classifications that receive double-weighting thereby reducing the requirements to perform two medium or one high-weighted activity to get full credit The classifications are as follows:

  • Non-patient facing, small practices or rural health clinicians

CMS publishes provider classifications for each performance year annually on its website, QPP.CMS.GOV, via its NPI lookup tool.

We know that managing your MIPS program can be a grueling task, and the changes to MIPS in 2020 are adding to the burden. abeo is here to support our clients with education on the program and submitting quality measure reports on your behalf. For more information, please contact your abeo Client Relations Manager (CRM).



abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

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