5% of MIPS Eligible Clinicians Earn a Negative Payment Adjustment

November 09, 2018 - Approximately 93 percent of eligible clinicians participating in MACRA’s Merit-Based Incentive Payment System (MIPS) in 2017 earned a positive payment adjustment, CMS Administrator Seema Verma recently reported.

“These results demonstrate that clinicians who engaged early and meaningfully participated experienced success,” the CMS leader stated in the official blog post.

About 91 percent of all eligible clinicians participated in the value-based reimbursement program’s first performance year, the federal agency reported in May 2018. And most of those providers will see their Medicare reimbursement increase in the 2019 payment year for their efforts.

Few eligible clinicians will receive a negative reimbursement adjustment in 2019, Verma reported in the blog post. Of the over 1 million MIPS eligible clinicians reporting in 2017, just five percent will see their Medicare reimbursement drop in 2019.

The small group of eligible clinicians could face a maximum negative payment adjustment of four percent based on their MIPS scores of zero points.

READ MORE: Maximizing MIPS Scores Through Chronic Disease Prevention

The majority of eligible clinicians reporting in 2017, however, will find their Medicare reimbursement increasing in the next payment year.

The new blog post revealed that 71 percent of the eligible clinicians will receive a positive reimbursement adjustment on top of an exceptional performance bonus based on their 2017 performance in MIPS. These providers scored between 70 and 100 points.

The maximum positive reimbursement adjustment the high-performing eligible clinicians will see is 1.88 percent.

Another 22 percent will just see the positive reimbursement adjustment in 2019 based on their MIPS scores, which ranged from 3.01 to 69.99 points in 2017, Verma reported.

The eligible clinicians earning a positive adjustment will face a maximum boost of 0.20 percent in 2019.

READ MORE: Developing a 2018 MIPS Reporting Strategy to Avoid a Penalty

The remaining two percent of eligible clinicians earned the minimum MIPS performance threshold of three points in 2017, meaning they will not see any payment adjustment in 2019.

CMS lowered the performance threshold in the 2017 performance year as part of a “Pick Your Pace” transition period in which eligible clinicians could report on just one quality measure to avoid a penalty in the 2019 payment year.

Clinicians also had the option of reporting for only part of 2017 for a modest positive adjustment or fully participating in the program for the full performance period for a larger positive adjustment.

Verma stated in the blog post that the “Pick Your Pace” flexibility was key to MIPS success in 2017 despite the transition period resulting in modest payment adjustments because of the program’s budget neutrality rules.

“This measured approach allowed more clinicians to successfully participate, which led to many clinicians exceeding the performance threshold and a wider distribution of positive payment adjustments,” she wrote. “We expect that the gradual increases in the performance thresholds in future program years will create an evolving distribution of payment adjustments for high performing clinicians who continue to invest in improving quality and outcomes for beneficiaries.”

READ MORE: How Can CMS Improve MACRA’s Quality Payment Program, MIPS?

The MIPS participation and performance flexibilities have been a point of contention for some stakeholders who want to earn higher payment adjustments for their performance in the value-based reimbursement program.

AMGA criticized the “Pick Your Pace” option in September 2016, arguing that the lower performance thresholds resulted in lower payment adjustments, which unfairly penalized eligible clinicians who prepared for MIPS implementation.

More recently, five Congress members from the House GOP Doctors Caucus argued that current low-volume thresholds and other exclusion policies for MIPS exempted too many Medicare providers from the program, resulting in less meaningfully payment adjustments.

CMS recently finalized the 2019 Quality Payment Program implementation rules and the federal agency upped the MIPS performance threshold to 15 points.

MIPS performance thresholds will also gradually increase until the sixth performance year when the threshold will be determined based on the mean or median of final scores from the previous period, the rules stated. At that time, eligible clinicians will qualify for the maximum adjustments according to MACRA.

In 2017, Verma reported that the overall national mean score for MIPS eligible clinicians was 74.01 points, and the national median was 88.97 points.

Eligible clinicians participating in MIPS through an Alternative Payment Model (APM) tended to earn higher MIPS scores, with a mean score of 87.64 points and a median score of 91.67 points.

Eligible clinicians participating in MIPS as an individual or a group, but not through an APM, received a mean score of 65.71 points and a median score of 83.04 points.

Verma also remarked that eligible clinicians practicing in small and/or rural practices were successful with MIPS reporting despite their unique challenges. On average, eligible clinicians in rural practices earned a mean score of 63.08 points, while clinicians in small practiced received a mean score of 43.46 points.

Building on the success of the 2017 performance period, CMS intends to continue providing customized no-cost technical assistance to eligible clinicians who earned a negative payment adjustment. The federal agency will also continue assistance for rural and small practices through the free Small, Underserved, and Rural Support initiative.

In general, the federal agency also aims to improve MIPS by reducing the administrative burden associated with the program. MIPS was rated as the top regulatory burden for practices in 2018, according to a recent MGMA poll.

“These are significant strides and we know that more work remains. While MIPS is required under law, I'm making a personal commitment to further reduce burdensome requirements and will work with you to make that a reality. Our obligation is to make this a practical program for every clinician, in both small and large practices. We take this responsibility very seriously,” Verma wrote.