This has not yet been finalized, so there is no telling what the new threshold will be - if it is, in fact, changed. That said, my bet is on 50 (because I am a pessimist at heart)... but that is purely a guess.
The original proposal had a tentative effective date as of 1/1/2020, so I believe 2019 data will still need to be submitted. (Anything could happen with the final rule, but I would absolutely plan to submit the 2019 data, as an effective date of 1/1/2020 would typically mean you don't have to collect and report 2020 data.)
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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