CMS Publishes CY 2020 Quality Payment Program Final Rule

On November 1, 2019, the Centers for Medicare & Medicaid Services (CMS) released CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies [CMS-1715-F and IFC], which includes changes related to Medicare physician payment and the Quality Payment Program (QPP) effective for services on January 1, 2020. The final regulations will be published in the Federal Register on November 15, 2019.

The final rule can be found here. CMS has also made available an overview fact sheet, an executive summary and a FAQ document as additional resources for the CY 2020 QPP final rule.

Merit-based Incentive Payment System (MIPS)

For the 2020 performance year (2022 payment year) of MIPS, CMS is increasing the performance threshold, the minimum MIPS score needed to avoid a negative payment adjustment, to 45 points (from 30 points). CMS also finalized a performance threshold of 60 points for the 2021 performance year (2023 payment year).

In response to feedback from participating clinicians, a recommendation from the Medicare Payment Advisory Commission and the agency’s analysis of the data from the initial launch of MIPS on the overall complexity of the program, CMS will begin to transition MIPS to the MIPS Value Pathways (MVP) framework beginning in CY 2021. Under the MVP, the clinician quality program will move away from reporting on activities and measures from the four performance categories (Quality, Cost, Improvement Activities and Promoting Interoperability) to a unified set of measures and activities centered on a specific condition or specialty.

Advanced Alternative Payment Models (APMs)

In the final rule, CMS comments that participation in Advanced APMs has increased from 2017 to 2018. The number of qualifying APM participants nearly doubled over that time from 99,076 to 183,306. The final rule makes several, technical changes to the QPP Advanced APM track, including adding a category of Aligned Other Payer Medical Home Models; modifying the definitions of marginal risk and expected expenditures for Other Payer Advanced APMs. The main area of activity for Advanced APMs is expected to occur outside of this rulemaking with the release of additional payment models, including the Direct Contracting application anticipated in the near future.

CMS Hosting Discussion on QPP Final Rule

On Wednesday, November 6 from 2:15 – 3:45 PM CMS will be hosting a call to discuss the PFS and OPPS/ASC final rules. Registration for this call can be found here.

Additional information about MIPS, MVPs, and APMs can be found on the QPP website.

Stay tuned for additional analysis from the McDermottPlus team on the CY 2020 QPP final rule.



For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459/ or Mara McDermott at 202-204-1462/