Recently, the Centers for Medicare & Medicaid Services (CMS) released performance feedback for clinicians included in the Merit-based Incentive Payment System (MIPS) for the 2020 performance year (PY).
Along with releasing performance feedback, we opened the targeted review period. A targeted review provides the opportunity for clinicians, groups, virtual groups or those participating in certain Alternative Payment Models (APMs) to request review of their MIPS payment adjustment factor(s), if they believe there is an error with their final score and associated MIPS payment adjustment.
The requests that we received through PY 2020 targeted review process caused us to take a closer look at a couple of prevailing concerns. The targeted review process worked as intended, as the incoming requests quickly alerted us to these issues and allowed us to take immediate action. Based on these requests, we reviewed the concerns and identified 2 issues that we needed to correct so that final scores align with our policies. In response, we corrected MIPS scoring logic which resulted in changes to performance feedback, including 2020 final scores and 2022 MIPS payment adjustments.
From the onset of QPP, our goals have included creating a program that is fully transparent and provides accurate information. We believe that the corrections identified below are essential to achieving that goal. We will continue to work closely with the clinician community to learn from one another and ensure operational excellence in implementation.
Complex Patient Bonus Correction for Medicare Shared Savings Program ACOs
Specifically, we determined that the complex patient bonus wasn’t added to the final scores of Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organizations (ACOs). This issue affected every Shared Savings Program ACO with MIPS eligible clinicians. In their updated performance feedback Shared Savings Program ACOs will see up to 10 complex patient bonus points reflected in their performance feedback and added to their final scores, if applicable. (There are approximately 20 ACOs that didn’t qualify for any complex patient bonus points.) As a reminder, your final score can’t exceed 100 points.
Patient-Reported Outcome Measure Correction
We also determined that our system didn’t recognize patient-reported outcome measures as outcome measures. We corrected our scoring logic, which resulted in 2 potential changes to quality performance category scoring for approximately 30,000 MIPS eligible clinicians:
- Patient-reported outcome measures submitted in addition to another outcome measure became eligible for 2 high priority bonus points. (As a reminder, these bonus points are capped at 10% of your quality denominator.)
- Patient-reported outcome measures became eligible to fulfill the requirement to report an outcome measure.
The majority of affected clinicians will see a modest increase in their quality performance category score and MIPS final score as a result of this correction. However, approximately 4,400 clinicians will see a decrease in their quality performance category score and MIPS final score. This occurred when a lower-scoring patient-reported outcome measure replaced a higher-scoring high priority measure in their top 6 measures, fulfilling the requirement to report an outcome measure. (A high priority measure is only selected for the top 6 measures in the absence of an available outcome measure.)
Impact to MIPS Payment Adjustments
The statute requires MIPS to be a budget neutral program, which, means that the projected negative adjustments must be balanced by the projected positive adjustments. As a result of changes to MIPS final scores from these 2 corrections, we reassessed the associated MIPS payment adjustments to maintain budget neutrality. Some clinicians that weren’t affected by the issues identified will see slight changes in their payment adjustment due to the reapplication of budget neutrality.
Additional Adjustment for Exceptional Performance
In addition to the standard MIPS payment adjustment, MIPS eligible clinicians with a final score between 85 and 100 points receive an additional adjustment for exceptional performance. This adjustment isn’t subject to budget neutrality but is scaled to ensure the appropriate distribution of available funds. When we corrected final scores for alignment with our existing policies, more clinicians moved into the exceptional performance pool, causing a slight decrease in the exceptional performance adjustment.
Sign-In to View Updated Feedback
The 2020 final scores and 2022 MIPS Payment Adjustments revisions were made to the performance feedback on the Quality Payment Program (QPP) website on September 27, 2021. We encourage you to sign-in to the Quality Payment Program website as soon as possible to review your performance feedback. If you believe an error still exists with your 2022 MIPS payment adjustment calculation, the targeted review process is available to you.
Targeted Review Extension
To offer additional time for clinicians, groups, virtual groups and APM entities and their participants to access and review their performance feedback, we’re extending the targeted review deadline to November 29, 2021 at 8:00pm (ET). You can submit a targeted review by signing in to the Quality Payment Program website.
We also have a number of resources available on our QPP Resource Library to help you understand your performance feedback and the targeted review process, including:
- 2020 MIPS Performance Feedback FAQs (PDF)
- 2020 Targeted Review User Guide (PDF)
- 2020 MIPS Scoring Guide (PDF)
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.