News & Insights

Are You Caught in the Crosshairs of QPP?

February 01, 2019

Are You Caught in the Crosshairs of QPP?


You may still be able to avoid a five percent penalty!


Year 1 - Payment adjustments realized

Year 2 - Submission window open now

Year 3 - Data collection needed

Below are a few important key items to consider before you get too far into 2019. 


  • 2017 payment adjustments are now being realized on 2019 Medicare Part B remittance advices (RA). 
  • Look for CARC and RARC codes. Positive MIPS payment adjustments are designated as 144 Incentive adjustment and N807 Payment adjustment based on MIPS. Negative MIPS payment adjustments are displayed on RAs as 237 Legislated/Regulatory Penalty. If you did not submit data in 2017, you may see a four percent reduction to most Part B payments in 2019.


  • The QPP portal is open. Eligible clinicians and groups can now submit and attest to 2018 MIPS measures and activities. The portal will close April 2, 2019. CMS has produced some helpful videos in the Resource Library to help you navigate the attestation process. 
  • HARP accounts will replace EIDM. 
  • If you haven't done anything yet, it may NOT be too late! Look at the Improvement Activity Inventory for 2018. You might have already completed what you needed to do to avoid a penalty. 


  • Get started reporting Quality! The 2019 Interactive Lookup tool has been updated.
  • Complete/update your Security Risk Assessment for the Promoting Interoperability category. The ONC, in collaboration with the HHS Office for Civil Rights (OCR), developed a new version of the downloadable Security Risk Assessment Tool (SRA Tool) to help guide you through the process. 
  • 2019 MIPS eligibility is not yet available online.

What's new?

  • Additional provider types included in MIPS: 
    • Physical therapists
    • Occupational therapists
    • Clinical psychologists
    • Qualified speech-language pathologists
    • Qualified audiologists
    • Registered dieticians and nutrition professionals
  • Final score calculation 


  • 30 points are needed to avoid a penalty.
  • 80 points is the threshold to earn an exceptional performance bonus.
  • There is a seven percent negative payment adjustment on all Medicare Part B services in 2021 for eligible clinicians who don't participate.
  • Claims submission is only allowed for individual/small practices.

Remember …

  • You don't have to have an EHR to avoid a penalty or earn a positive adjustment or bonus.
  • It does not cost you any money to submit data.

If you are an eligible clinician, a LAMMICO insured and have not already implemented a process for capturing or reporting MIPS data in your practice, contact LAMMICO and let us help you! If you already have a MIPS process, we can be an additional resource and discuss options regarding MIPS. There is no charge for our consultation. These services are provided to you because you are a LAMMICO insured. 

Participation in the Quality Payment Program may also help you mitigate your malpractice risk through tracking and improving quality care (Quality measures), increasing patient engagement and satisfaction (Improvement Activities) and improving communications using secure electronic transmissions between providers and with patients (Promoting Interoperability). 


 Contact LAMMICO Practice Management Specialist, Natalie Cohen, MBA, MHA, at 504.841.2727 or

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