Every year the most significant news that comes from the proposed rule and later the final rule is the increase in the performance threshold, otherwise known as the minimum score an eligible clinician must achieve to stay penalty-free. The proposed rule in 2020 aims to set the performance threshold for both 2020 and 2021, moving the minimum point values to 45 and 60 points respectively.   This is up from 30 points in the performance year 2019.

The second piece of information that most practices want to know is the exceptional performance threshold. This is the point value needed to reach extra incentive money outside of budget neutrality, and from where the bulk of the positive payment adjustment comes. The proposed change to the exceptional performance will require eligible clinicians to reach 80 points in 2020 and to 85 points in 2021.

We know the performance categories’ weights are always in flux year after year. This is due to the mandated rise of the Cost performance category to gradually work toward equal weighting with Quality as required by law beginning with the sixth year of the program (2022 performance year). The table below shows the proposed performance category weights for the next two years, seemingly moving toward the even 30% weight for Quality and Cost in 2022.

2020 Performance Year Proposed

2021 Performance Year Proposed

  • Quality: 40%
  • Cost: 20%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%
  • Quality: 35%
  • Cost: 25%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%

A new philosophy CMS is proposing beginning with the 2021 performance year is called MIPS Value Pathways (MVPs), a conceptual participation framework that would apply to future proposals. This idea looks to reduce the reporting burden of specialists and the goal is to move away from rigid categories for activities and measures and move towards an aligned set of measure options more relevant to a clinician’s scope of practice that is meaningful to patient care. The MVP framework would aim to align and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS for different specialties or conditions. A clinician or group would be in one MVP associated with their specialty or with a condition, reporting on the same measures and activities as other clinicians and groups in that MVP. This is something to be on the look-out for in upcoming years.

Finally, several policies have changed in the last two years that have no proposed change in 2020. The eligible clinician types that had new additions in 2019 will potentially remain unchanged in 2020. The Low-volume threshold of $90,000 for Medicare Part B covered services, 200 Part B patients, and 200 or more covered professional services should remain intact for eligible clinicians. Facility-based scoring for those billing at least 75 % of covered professional services in a hospital setting will remain. The scoring methodologies and bonus point availability should stay true to 2019 form.