Practices that reported under the Merit-based Incentive Payment System (MIPS) of the Quality Payment Program (QPP) for 2023 can now get their performance score and find out how it will impact their Medicare reimbursement in 2025. The first step is to sign in to the QPP website to get your own practice’s results and review it for any discrepancies. The Centers for Medicare and Medicaid Services (CMS) has released the 2023 MIPS Performance Feedback FAQ’s as a guide to learning more about your practice’s performance.

The maximum upward adjustment for practices with a perfect score of 100 points on their 2023 performance is currently expected to be 2.15%. That figure could change with a final reconciliation after all reviews have been completed. The payment threshold for 2023 was 75 points; practices that scored more than the threshold will receive a positive adjustment up to the maximum, while practices that scored below the threshold will see their Medicare payments reduced by up to 9% in 2025.

This table shows the history of MIPS positive adjustments:

The budget-neutral design of the QPP is such that positive adjustments are greater when there are large negative adjustments. As the criteria for obtaining a positive adjustment become increasingly difficult to meet, more radiology practices could fall into the negative adjustment category, allowing non-radiology specialties to be rewarded with a higher positive adjustment.

The 2022 result was a much higher adjustment than it had been in any of the preceding years, and higher than the 2023 maximum. The 8.25% adjustment included 6% from the Exceptional Performance Bonus and 2.25% from the Base Adjustment. 2022 was the final year the Exceptional Performance Bonus was available. Part of the reason for the 2022 bump could be that in the earlier years there were fewer practices facing a negative adjustment, with the result that positive adjustments were reduced through budget neutrality; it was once far easier to avoid the penalty. Additionally, during the 2020 and 2021 public health emergency years, many practices were able to qualify for a hardship exception, further reducing the amount of negative adjustment and therefore limiting the amount of upward adjustment. For 2023, scoring largely returned to normal with fewer hardship exceptions being applied for.

Some practices might continue to be impacted by a Cost Performance category score, which started to become a more common factor for radiology practices in the 2022 performance year. While many radiologists will not have any score for Cost, those that perform a significant amount of Evaluation and Management (E/M) services could trigger scoring in this category. Practices that feel they have been negatively impacted by the Cost category or any other aspect of the MIPS scoring process may request a Targeted Review. The request for a targeted review must be filed by October 11, 2024, for the 2023 performance year, which is 60 days after the payment adjustments were announced. Detailed information is available by downloading the MIPS 2023 Targeted Review Guide.

Practices should access their scores as soon as possible and review the results carefully. Any questions about possible errors should be resolved by filing for a Targeted Review. The payment adjustment based on the 2023 performance scores will be applied to Medicare payments in 2025.

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Erin Stephens, CPC, CIRCC  is the Sr. Client Manager, Education at Healthcare Administrative Partners. 

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