MIPS 2020 Final Rule: Quality

As practices move into 2020, reporting on MIPS (Merit-based Incentive Payment System) or not reporting can make a significant difference in reimbursements. To do nothing and not report on any measures can mean a 9.0 percent penalty in Centers for Medicare & Medicaid Services (CMS) payment adjustments for the 2020 reporting year. That +/- 9 percent will remain in effect for each year going forward, according to CMS.

For that reason, the Quality Reporting Engagement Group strongly advises you to report your data to earn a performance score. Even performance scores that just meet the minimum thresholds can avoid a downward adjustment.

Each year CMS adjusts the performance categories. We will address the four categories over a few blogs.


There were minor changes made to the Quality category from 2019 reporting to 2020 reporting years. The category weight in the total performance score stays at 45 percent, as it was in 2019. By performance year 2022, CMS mandates the weighting to decrease to 30 percent of the total score as the Cost category increases.

CMS also requires that the data completeness threshold move to 70 percent, including both Medicare and non-Medicare patients. This means that you must report on at least 70 percent of all Medicare and non-Medicare patients and/or visits for the Quality measures you submit. The rationale for this increase is that the average data completeness rates for eligible clinicians, groups and small practices are all already over 74 percent. The data completeness threshold will not include the Web Interface or Consumer Assessment of Healthcare Providers and Systems (CAHPS), which are based on Medicare sampling.

For large practices (16 or more ECs), any measures not meeting the data completeness threshold will get zero points. Small practices will continue to receive three points.

It is also recommended that practices review their measures as soon as possible to see if they were removed or changed – as 42 measures were removed this year. CMS did introduce modified benchmarks that will initially have limited use, to include only two measures in 2020:  Diabetes: Hemoglobin A1c (HbA1c) Poor Control and Controlling High Blood Pressure. These two measures will not be scored with the regular decile scoring, but rather be considered in a flat percentage benchmark – to avoid incentivizing inappropriate treatment for patients. CMS could propose to add measures to this modified benchmark scoring in future years.

For 2020 MIPS reporting, your practice or eligible clinicians will:
  • Choose 6 Quality measures
  • Report over the 12-month calendar year
  • Potentially choose multiple collections types
  • Meet 70 percent data completeness

Information for this article was taken from the MIPS 2020 Final Rule webinar presented in January by the Quality Reporting Engagement Group. The team is ready to assist with all your MIPS needs, from submission assistance for 2019 reporting to a full-service consulting partnership for 2020. Contact them at sales@intrinsiq.com.


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