The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website. The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results. According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold.
Exactly how this will translate into an adjustment factor for 2020 is not yet known. The MIPS program is designed to be budget-neutral, which means that for every positive adjustment there has to be a corresponding negative adjustment. With such success by the physician community in meeting the target, we can only assume that the financial rewards will be minimal. However, achieving a final score of at least 70 points entitles clinicians to participate in the Exceptional Performance bonus, which is a $500 million fund available separately from the general MIPS budget neutrality calculation.
Qualifying Advanced Alternative Payment Model (Advanced APM) participants nearly doubled in 2018, according to the report, and those participants will receive a 5% incentive payment. As we reported in our article What Does APM Participation Mean for a Radiology Practice, there certainly are benefits for radiology groups to participate in Advanced APMs, even beyond the Medicare program, but unfortunately there are few opportunities as these models are geared toward primary care rather than diagnostic practices.
The information released indicates that the Medicare Physician Compare website has been updated with 2017 Quality Payment Program (QPP) performance information. However, our research failed to disclose the performance scores and we understand that this could be delayed. When CMS does post the information, physicians’ profile pages will be updated with 12 MIPS quality measures, 8 Consumer Assessment for Healthcare Provider and Systems (CAHPS) survey measures, and 17 Qualified Clinical Data Registry (QCDR) quality measures reported by groups and individual clinicians. CMS says that you can learn more about how Quality Payment Program performance information is selected for public reporting on Physician Compare in the Quality Payment Program and Physician Compare Factsheet: What You Need to Know for Performance Year 2017.
The report on 2018 participation shows that QPP participation is becoming more routine for physicians, and the performance by those participants is achieving all-time high levels. This will undoubtedly lead to more topped-out measures (those measures whose median performance score is 95% or higher and whose performance is “so high and unvarying that meaningful distinctions and improvement in performance can no longer be made”) with the result that new, more difficult standards will be put in place. In the long run, the positive rewards for QPP participation will be diminished while the penalties for non-participation will remain significant. Achieving a final score that earns the Exceptional Performance bonus will maximize a practice’s positive Medicare fee schedule adjustment. Subscribers to this blog will be best positioned with information to earn the highest possible reimbursement as the QPP evolves.
Erin Stephens is the Sr. Client Manager, Education at Healthcare Administrative Partners.
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