September 27, 2018

CMS may have gotten your MIPS adjustment wrong. Here's what you need to know.

Daily Briefing

    Read Advisory Board's take: 3 things to keep in mind about this update

    CMS this month announced it had identified errors in its quality scores for clinicians participating in the Merit-based Incentive Payment System (MIPS) track under MACRA's Quality Payment Program (QPP).

    MACRA details

    Under MACRA's Quality Payment Program, which took effect in 2017, eligible professionals can choose from two payment tracks:

    • The Advanced Alternate Payment Model (Advanced APM) track, for clinicians who take on a significant portfolio of Advanced APMs, which include risk-based accountable care organization (ACO) models; or
    • MIPS, for providers who are reimbursed largely through fee-for-service.

    Although physician pay in the MIPS track largely follows a traditional fee-for-service structure, CMS adjusts eligible professionals' pay based on how they "score" in four categories of metrics: advancing care information, cost, improvement activities, and quality.

    Based on those scores, CMS determines whether eligible clinicians will receive penalties or bonuses of up to 4% beginning in 2019. That percentage will increase to up to 5% in payment year 2020, and rise incrementally until it reaches 9% in payment year 2022.

    CMS identifies error and updates 2017 MIPS final scores

    Earlier this month, CMS released a statement that said the agency had identified and corrected errors in the way it calculated 2017 performance feedback that could result in changes to 2017 MIPS scores and 2019 MIPS payment adjustments.

    CMS said the errors were caught through the agency's targeted review process, which allows clinicians, groups, and those participating in certain APMs to request the agency take a second look at their MIPS payment adjustment factors if they suspect there is an error in the calculation.

    The agency said several providers had flagged errors related to the application of:

    • The 2017 advancing care information and extreme and uncontrollable circumstances hardship exceptions;
    • The improvement activity credit for successful participation in the improvement activity reduction study; and
    • The all-cause readmission measure to the MIPS final score.

    CMS said it has corrected those problems and re-calculated the associated MIPS payment adjustment rates. The agency also extended the deadline for clinicians to submit a request for a targeted review from Sept. 30 to Oct. 15.

    Reactions to the error

    Provider groups have said the details of the error are still largely unclear.

    David Introcaso, AMGA's senior director of regulatory and public policy, said the error, "Reinforces the complaint that the program may be or is too complicated."

    Jaan Sidorov, CEO of the Care Centered Collaborative, agreed, saying, "The scoring and payment logic can give the unfortunate impression that the CMS leadership is making things up as they go along, which is only adding to the unease of MIPS' critics" (Ellison, Becker's Hospital CFO Report, 9/25; Dickson, "Transformation Hub," Modern Healthcare, 9/21; CMS 2017 MIPS Performance Feedback, 9/13).

    Advisory Board's take

    Tony Panjamapirom, Senior Consultant, Quality Reporting Roundtable

    The results of the re-calculation are likely a tough pill to swallow: due to the changes, providers with a positive adjustment are generally seeing less of a payout now than when the results were first announced in July.

    This is due to the budget neutral nature of the MACRA program, which requires CMS, by law, to re-calculate the associated payment adjustment rate for all MIPS eligible clinicians. As a result of this balance, providers' performance rate was reduced, which subseque ntly has led to lower positive payment adjustments or incentives. One of our members indicated that their previous 2.02% positive adjustment (based on the maximum 100-point MIPS final score) is now reduced to 1.88%.

    Learning that they're going to receive less reimbursement, especially for those who worked so hard to achieve high performance and anticipated a better return, is frustrating to many providers.

    “We recommend that every MIPS provider logs back into the QPP website and re-reviews their 2017 MIPS final score”

    As a first response, we recommend that every MIPS provider logs back into the QPP website and re-reviews their 2017 MIPS final score and associated 2019 payment adjustment rate. If you believe that the updated performance feedback is incorrect, you may submit a request for Targeted Review. CMS extended the deadline for this review to October 15, 2018.

    We also suggest that you keep three things in mind about this update to the payment adjustment rates:

    1. This is the first year that CMS has taken on a program of this caliber with such complex requirements and far-reaching impacts. CMS is still smoothing out the whole program and how they are implementing their policies.

    2. It's a good thing that CMS fixed these issues now because many providers around the country found a lot of errors with their initial performance feedback reports.

    3. This may not be the last time that your MIPS final score and 2019 payment adjustment are changed. If CMS identifies additional issues and errors, don't be surprised if they make another announcement to further modify these rates before 2019.

    If you're still sorting out MIPS, what categories are included and how to achieve success with the program, we recommend looking at our MIPS Toolkit which has a number of resources to help.

    Access the Toolkit

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