Now that everyone has had the chance to see their “underwhelming” scores for 2017 MIPS reporting, the industry is gearing up for year three of the MIPS Program. 

By now, most of you should have your process down pat and have become practiced at not only the measures that work best for your clinic, but also how to optimally collect relevant data as well as achieve a positive score for your practice.  We are getting the hang of things!

While the 2019 MIPS Final Rule is not anticipated until November, it is important to know about a couple of changes that may come to fruition (based on the Proposed Rule) in 2019 for MIPS.  Unfortunately for those wishing for shorter reporting requirements, that will not be the case – 12 months is still required for Quality and Cost Categories under MIPS. 

What stays the same in 2019:


  • Participation thresholds remain >200 Medicare patients or >$90,000 in annual billing or >200 professional services (i.e., more than 200 visits and/or procedures on a Medicare patient)
  • Reporting Requirement
  • 12 months for Quality and Cost
  • 90 Days for Promoting Interoperability (PI) and Improvement Activities (IA)

Some of the Major 2019 Proposed Changes:


  • New Eligible providers:  Physical Therapists, Occupational Therapists, Clinical Social Workers, Clinical Psychologists
  • New Opt-In Option: If you meet only ONE (but not all) of the above participation thresholds you can choose to report MIPS to receive a possible positive adjustment in 2021.  For all you go-getters, this is your opportunity to show your stuff.

Minimum Threshold to avoid negative 2021 payment adjustment:

  • Minimum is 30 points… double the 15 point threshold in 2018

Category Weights:

  • Quality: 45% (Down from 50% in 2018)
  • PI: 25%
  • IA: 15%
  • Cost: 15% (Up from 10% in 2018)


  • Must use 2015 CEHRT EMR in 2019. Credit for 2014 CEHRT is no longer permitted.

2019/2021 Adjustment

  • +/- 7% impacting payments in 2021, increased from 5% in 2018 impacting 2020 fees.

While we wait for the final rule to be posted, one thing is for sure – stay the course!  Get your processes tweaked as needed, check the certification of your EHR, and if you are a newly Eligible Clinician, talk to Patient360 to get your process in place so you are ready to go on January 1st!!