Breaking Down the MIPS 2020 Proposed Rule

Distilling the MIPS 2020 Proposed Rule Down to the Essentials

On July 29, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2020 Proposed Rule for the Medicare Physician Fee Schedule (PFS), which included proposed changes to the Quality Payment Program (QPP). The PFS policy dictates Medicare rates and policies under Part B, while the QPP policy outlines two major value-based payment programs: the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). The rule is very long at over 1700 pages!

We are excited to bring you the MIPS highlights, section-by-section to give you the most pertinent bullets that will set you up for success in the 2020 reporting year.

MIPS Program Overview

  • The threshold to avoid a penalty is changing. Performance threshold is rising from 30 points to 45!
  • The category weights continue to evolve. The relationship here continues to be one where the category weight for Cost increases in line with the category weight for Quality decreases.
  • MIPS Value-based Pathways (MVP) is a new concept to get prepared for in 2021.


 Quality Category

  • Category weight decreases to 40 percent of the complete performance score
  • 365-day reporting period continues
  • Data completeness requirement increases to 70 percent

Promoting Interoperability Category

  • Requires 2015 Certified EHR Technology (CEHRT)
  • 90-Day Reporting Period continues
  • Clinicians who qualify for an exemption in the PI category will have the 25 points redistributed to the Quality category
  • Performance-based scoring for each Objective and Measure continues
  • Security Risk Analysis (SRA) will remain a scoreless pre-requisite to earn any points in this category
  • CMS proposes to remove the Verify Opioid Treatment Agreement bonus measure in MIPS 2020.
  • CMS plans to keep the Query of the Prescription Drug Monitoring Program (PDMP) measure as an optional bonus measure. However, reporting will be a “Yes” or “No” instead of a numerator and denominator.
  • CMS is looking for feedback regarding:
    • A metric to improve the efficiency of providers within EHRs
    • Engaging in activities that promote the safety of the EHR itself

Improvement Activities Category

  • More than 100 activities to choose from
  • Double-check the activities you plan to use! CMS proposed the following changes to this category:
    • Added 2 improvement activities
    • Modified 7 improvement activities
    • Removed 15 improvement activities
  • Most importantly, CMS is increasing the participation threshold for group reporting such that to receive credit for an activity, at least 50 percent of the clinicians in the practice must participate in the activity for at least a continuous 90 days. This is up from a single clinician in the 2019 program year.  

Cost Category

  • Category weighted increases to 20 percent of the complete performance score.
    • CMS states this category weight will continue to rise to 25 percent in 2021 and  30 percent in 2022.
  • 365-day reporting period continues, tracked through administrative claims
  • Changes to two of the measure types: Medicare Spending Per Beneficiary measure and Total Per Capita Cost:
    • Assign responsibility for services to a larger number of clinicians
    • Improve risk adjustment timeline
    • Avoid assigning costs that are incurred before a clinician begins providing services to a patient
  • The number of episode-based measures is proposed to increase from 8 to 18 by adding the following 10 new measures:
    • Acute Kidney Injury Requiring New Inpatient Dialysis
    • Elective Primary Hip Arthroplasty
    • Femoral or Inguinal Hernia Repair
    • Hemodialysis Access Creation
    • Inpatient Chronic Obstructive Pulmonary Disease (COPD) Exacerbation
    • Lower Gastrointestinal Hemorrhage
    • Lumbar Spine Fusion for Degenerative Disease, 1-3 Levels
    • Lumpectomy Partial Mastectomy, Simple Mastectomy
    • Non-Emergent Coronary Artery Bypass Graft (CABG)
    • Renal or Ureteral Stone Surgical Treatment

A Final Note

We want to remind everyone that this is a proposed rule. While the CMS approach for the 2020 Performance Year is to maintain many of the requirements from the 2019 Performance Year while providing some needed updates – IT IS NOT FINAL and changes are both possible and expected. So, please if you are pouring over the full document, keep this in mind because we expect to see and deliver finalized guidance closer to year-end. 

Are you in need of support to succeed in MIPS? We are here to help. Join the ranks of our exceptional performers. Contact us today for a free consultation 888-647-7247 or 

Additional Resources

If you would like to read all 1700+ pages of the full proposal you can find it here.

We prefer the CMS proposed fact sheet, which can be downloaded here!


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