Avoiding the MIPS Penalty in 2019 #PACPearls

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By Dr. Mark Kaufmann

The bar has been raised.

The amount of MIPS points required to be exempted from the 7% penalty in 2021 (for performance year 2019), is DOUBLE what it was last year. Instead of 15 MIPS points, you now need to get 30 MIPS points. With a little more effort, there is still a way to avoid the MIPS penalty in 2019, and while it’s still possible to do this without using a registry OR an EHR, both of them would make it a lot easier.

Here’s how to get it done:


  • If you are a small (fewer than 15 clinicians) practice, each clinician needs to complete five measures on at least one patient. I still recommend that each clinician complete five measures on more than one patient. Any combination of measures will do, and five will give you 15.75 points.
  • In order to get up to 30 MIPS points, you will also need to do a High Weighted Improvement Activity (IA).
  • You can choose any of the high weighted IAs from the 2019 Improvement Activities List, and if you want to do it without a registry or EHR, I would recommend doing the Complete CDC Training in Antibiotic Stewardship.
  • Without a registry, you would have to attest to completing the IA by using the CMS QPP website, which is probably more difficult than doing the IA itself!
  • If you use a registry, like DataDerm, they will attest for you…and by the way, it’s probably the right time to consider getting DataDerm, as this will probably be the last year that I will be able to write this type of cheat sheet.
  • Starting next year, you will have to choose between getting “in the game” or, taking a 9% penalty every year moving forward.


Food for thought.


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