CMS recently released a blog post and infographic on preliminary participation data for the Quality Payment Program (QPP) in 2019. The data gives us a look at what incentives providers will receive in 2021, based on their 2019 performance.
Under MACRA's Quality Payment Program (QPP), which took effect in 2017, eligible clinicians can choose from two payment tracks:
- The Advanced APM track, for clinicians who take on a significant portfolio of Advanced APMs, which include risk-based accountable care organization (ACO) models; or
- Merit-based Incentive Payment System (MIPS), for providers who are reimbursed largely through fee-for-service. CMS adjusts eligible clinicians' pay based on how they "score" in four categories of metrics: Quality, Cost, Improvement activities, and Promoting interoperability.
Clinician participation steady in 2019—but Covid-19 means fewer receive positive payment adjustments
Overall, there were few surprises in how providers fared across the two QPP payment tracks for 2019.
For the Advanced APM track, 195,564 clinicians earned Qualifying APM Participant (QP) status to participate in the APM track, up from 183,306 in 2018. They'll receive the 5% lump sum bonus—QPP's reward for clinicians who participate in downside risk models like the Next Generation accountable care organization (ACO).
For the MIPS track, 954,604 clinicians participated in MIPS, down from 1.2 M clinicians in 2018. A significant portion performed well, with 83.69% earning a score above the exceptional performance threshold. Those clinicians will receive positive payment adjustments to their future Medicare Part B reimbursements, but the adjustments remain low. The maximum positive adjustment topped out at 1.79% for clinicians who earned the highest possible MIPS score of 100 points.
In MIPS, positive payment adjustments were expected to be small for the 2021 payment year because CMS allowed providers to avoid penalties in MIPS if they were unable to submit data, in response to the Covid-19 pandemic. Just 0.32% of MIPS eligible clinicians will receive a negative adjustment based on the 2019 program year. Because MIPS is budget neutral, the few penalties being collected also limits the amount of positive adjustments that can be paid out. But by law, there is a separate pool of funds set aside for exceptional performance. That means only exceptional performers (those who scored at or above 75 points) will see a MIPS incentive.
Beyond the MIPS participation data, there were 27,995 Partial Qualifying APM Participants (partial QPs) who just missed the QP threshold in 2019. For comparison, there were just 47 in 2018. The increase in the number of Partial QPs corresponds to the increase in QP payment and patient counts thresholds in 2019. This is important because, partial QP status does not qualify clinicians for the APM track, so they're not eligible to receive the 5% APM bonus. But they can potentially receive a payment adjustment by opting into and performing well in MIPS.
The QP thresholds stay steady in 2020 but are scheduled to increase again in 2021. That means even more providers in APMs could narrowly miss making it into the APM track. We encourage providers who currently enjoy QP or Partial QP status to evaluate their MIPS strategy should they miss out the APM track in future years.
How Covid-19 could impact MIPS payments going forward
Timing of Covid-19 had little impact on data submission—for now. CMS introduced an Extreme and Uncontrollable Circumstances (EUC) policy to reduce reporting burden as the public health emergency surged. Only 6.83% of MIPS eligible clinicians received reweighting of one or more performance categories through this policy. This relatively low number appears to reflect the timing of the pandemic. Most clinicians were well prepared to report their MIPS data despite the submission period coinciding with the first wave of Covid-19 infections. But circumstances for 2020 are very different, and we may see more EUC applications from health systems hit especially hard by the pandemic throughout the 2020 performance year.
If that's the case, we can expect so see a similar payment adjustment dynamic in 2022, based on 2020 performance. If clinicians can easily avoid penalties in MIPS, it's highly likely we'll continue to see only exceptional performers earn positive payment adjustments in the program. However, it will be slightly harder to achieve exceptional performance next year, as the threshold has been set at 80-points for the 2020 performance year.