2019 MIPS Step-by-Step Guides

Below are step-by-step guides on calculating, collecting and reporting each MIPS performance category: Quality (45 final MIPS points), Promoting Interoperability (PI) (25 final MIPS points), Clinical Practice Improvement Activities (CPIA) (15 final MIPS points), and Cost (15 final MIPS points). The Cost category does not require data submission and is scored through claims submitted to Medicare.

A maximum of 100 final MIPS score can be earned by achieving the full points in each category.

Practices will need to submit data for at least two of categories* to receive enough points to avoid a 7% penalty to their Medicare Part B Fee Schedule in 2021. For 2019 the minimum final MIPS score amount must be greater than or equal to 30 MIPS points to avoid the penalty. Any MIPS score achieved over 30 points could provide an incentive payment, anything below 30 points will result in a penalty.

For more information about the MIPS program and steps to take on getting started please review our MIPS web page.

*Although the Quality category alone offers enough final MIPS points to meet the 30-point benchmark, we highly recommend submitting data for an additional category. Quality category points are awarded on a sliding scale and are dependent upon performance of each individual measure reported, therefore the 45 final MIPS points for Quality is not guaranteed simply based upon participation. 

QUALITY Step-by-Step Guide (PDF file)

QUALITY Point Calculation

The Quality category accounts for 45 final MIPS points out of the possible 100 final MIPS score. This category requires a year’s worth of data (Jan. 1 through Dec. 31, 2019) on six selected measures. Each measure is worth up to 10 points (allowing for 60 category points total) and depending on performance physicians/practices will receive between one and 10 points per measure. Below is an example* of how this category would be scored:

Dr. Smith reported on 6 quality measures. On three of her measures she received the full 10 measure points, but on the other three she was only able to achieve 5 measure points each.

(10 points x 3 measures) + (5 points x 3 measures) = 45 category points
45 category points ÷ 60 category points possible = .75 or 75%

Because Dr. Smith achieved 75% of her category points, she can apply 75% of the 45 final MIPS Quality points available to her final MIPS score:

45 final MIPS Quality points x .75 or 75% = 33.5 final MIPS points.

Dr. Smith’s FINAL MIPS Quality score is 33.75 points, which will be counted towards her final MIPS score. This point total is more than the 30 MIPS points benchmark, therefore Dr. Smith will avoid a 7% penalty on her 2021 Medicare payments even if she chooses to only participate in the Quality category. Additionally, Dr. Smith could potentially receive an incentive payment for achieving > 30 MIPS points.

*This example does not consider any possible bonus points practices could achieve such as the small practice bonus and others offered within MIPS.

PI Step-by-Step Guide (PDF file)

PI Point Calculation

The PI category (previously the ACI category or Meaningful Use) accounts for 25 final MIPS points out of the possible 100 final MIPS score. This category requires a performance period of at least 90 consecutive days within 2019.

In 2019, unlike 2017 and 2018, there is a single set of Objectives and Measures to report. This single measure set includes new and existing Promoting Interoperability performance category measures organized under 4 objectives. Measures are no longer classified as base score or performance score measures.

For 2019 the PI category REQUIRES the use of 2015 Edition Certified EHR Technology (CEHRT) for participation. Participants must submit collected data for certain required measures from each of the four objectives measures (unless an exclusion is claimed) for 90 continuous days or more during 2019.

In addition to submitting measures, clinicians must:

• Submit a “yes” to the Prevention of Information Blocking Attestation;
• Submit a “yes” to the ONC Direct Review Attestation; and
• Submit a “yes” for the security risk analysis measure.

Total available category points are 110 with a maximum capped category score of 100 points (10 bonus points available to make total possible 110). 

The total PI performance category score will then be multiplied by the 25 final MIPS PI points available. This product is then added to the overall MIPS final score.

For example:

Dr. Smith’s EHR is 2015 certified. After completing all the required PI measures Dr. Smith achieves 80 category points.

80 category points ÷ 100 category points possible* = .8 or 80%

*We use 100 category points possible for this calculation rather than the total possible of 110 because this category is capped at 100 points. 

Because Dr. Smith achieved 80% of her category points, she can apply 80% of the 25 final MIPS ACI points available to her final MIPS score:

25 final MIPS ACI points x .80 or 80% = 20 final MIPS points

Dr. Smith’s FINAL MIPS ACI score is 20 points, which will be counted towards her final MIPS score. This point total does not meet the 30 MIPS points benchmark; therefore Dr. Smith need to submit data for another category along with the PI category to reach the 30-point benchmark and avoid a 7% penalty on her 2021 Medicare payments.

CPIA Step-by-Step Guide (PDF file)

CPIA Point Calculation

The CPIA category accounts for 15 final MIPS points out of the possible 100 final MIPS score. This category requires each activity selected to be implemented within your practice for at least 90 consecutive days during 2019.

This category is attestation based, meaning when it is time to report only a “yes” or “no” statement is required for each activity completed. No documentation is required to be submitted but be sure to keep record of the activity completion in case of audit by CMS.

There are two levels of activities “medium” weighted or “high” weighted activities. Small practices (15 clinicians or less) are required to complete one high weighted activity (each worth 40 category points) or two medium weighted activities (each worth 20 category points) to achieve a full 40 out of 40 category points resulting in receiving the full 15 final MIPS points towards their final MIPS score. Below is an example:

Dr. Smith works in a practice of 10 clinicians (considered a small practice). The practice has selected 2 medium weighted activities to complete for 2019 (activities completed by a practice can be attested to by an individual or group).

(1 medium activity x 20 points) + (1 medium activity x 20 points) = 40 category points
40 category points ÷ 40 category points possible = 1 or 100%

Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 15 final MIPS CPIA points available to her final MIPS score:

15 final MIPS CPIA points available x 1 = 15 points

Dr. Smith’s FINAL MIPS CPIA score is 15 points, which will be counted towards her final MIPS score. This point total does not meet the 30 MIPS points benchmark; therefore Dr. Smith need to submit data for another category along with the CPIA category to reach the 30-point benchmark and avoid a 7% penalty on her 2021 Medicare payments.

Larger practices (greater than 15 clinicians) will be required to do double the amount of activities to achieve a full 40 category points and get their 15 final MIPS points. Medium weighted activities for large practices are worth 10 category points each (requiring four be completed to achieve 40 points) and high weighted activities are worth 20 category points (requiring two be completed to achieve 40 points).

Note: A combination of high and medium weighted activities may be completed to achieve a full category score as long as a total of 40 category points are achieved.

Cost Point Calculation  

Cost is not manually submitted and is measured behind the scenes at CMS using administrative claims data. Total number of category points available in the Cost category is determined by which measures apply to your practice, the maximum category points with all included measures is 100 points (10 eligible measures, up to 10 points each measure). Below is a points example for illustrative purposes only:

Dr. Smith was informed by CMS that she was only eligible for 7 out of the 10 measures. She received 10 points on all 7 measures she was scored on.

Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 15 final MIPS CPIA points available to her final MIPS score:

15 final MIPS Cost points available x 1 = 15 points

Final MIPS Score for Dr. Smith:

(Final MIPS Quality Score = 33.75 ) + (Final MIPS PI Score = 20)  + (Final MIPS CPIA Score = 15)  + (Final MIPS Cost Score = 15) = Total Final MIPS Score = 83.75

With a final score of 83.75 out of a possible 100, Dr. Smith will avoid a 7% penalty to her 2021 Medicare Part B payments and will mostly likely receive incentive payments as well.