HAP Radiology Billing and Coding Blog

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 rules and requirements for success in the Medicare Quality Payment Program (QPP) are ever-changing, and it seems like each year brings a new challenge for practices to avoid a payment penalty or, hopefully, to earn a payment bonus. Most recently, CMS announced that the 2023 data submission deadline would be extended until April 15, 2024, due to the cyberattack at Change Healthcare in February, and that practices affected by the cyberattack could apply for an Extreme and Uncontrollable Circumstances (EUC) Exception. The EUC exception allows the applicant to request reweighting of any or all of the performance categories under the Merit-Based Incentive Payment System (MIPS).

For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost. Several factors have combined over the past few years to change the goal for radiology practices – it is now ‘penalty avoidance’ rather than a reward for reporting quality metrics. As we outlined in our recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.

Today's Quality Payment Program (QPP) began in 2006 as the Physician Quality Reporting Initiative (PQRI). It was a voluntary program that would earn participants a bonus payment of 2% of their prior-year Medicare reimbursements. Beginning with performance year 2013 (for payments in 2015) a penalty was imposed on those physicians who did not successfully report quality data. The 2016 performance year saw the initiation of the Value-Based Payment Modifier (VM) that allowed for upward, downward, or neutral payment adjustments in 2018 based on both the quality and cost of care delivery. In the first year the VM was applied, physicians with low cost and high quality earned an additional 9.78% over the basic Medicare fee schedule while the potential negative adjustment for not reporting, or not successfully reporting, was 6%. There was a lot of incentive to participate in the program at as high a level as possible!

Beginning in 2023, physicians will have the option to report under the Medicare Quality Payment Program (QPP) using MIPS Value Pathways (MVP) in lieu of the traditional reporting methods. MIPS, the Medicare Incentive-based Payment System, started gathering performance reports in 2017 and in 2019 the first Medicare payment adjustments were made based on that 2017 reporting. Eventually traditional MIPS reporting will be phased out, but the Centers for Medicare and Medicaid Services (CMS) has not proposed a timeline for doing so.

The Centers for Medicare and Medicaid Services (CMS) press release announcing the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2023 highlights expanded access to behavioral health services, Accountable Care Organizations (ACO), cancer screening, and dental care. Of these areas, cancer screening could be important to radiology practices, but the news was not good – CMS declined to include CT colonography coverage while it expanded coverage for traditional colonoscopy. The MPFS regulates the Medicare fee schedule payment provisions as well as the Quality Payment Program (QPP).

The Centers for Medicare and Medicaid Services (CMS) announced that they have adjusted certain aspects of the Quality Payment Program (QPP) in response the Public Health Emergency (PHE) caused by the COVID-19 coronavirus outbreak.  CMS has extended the deadline for reporting 2019 Merit-based Incentive Payment System (MIPS) data and has relaxed the criteria for avoiding a penalty in 2021 based on submission of 2019 data.

Participation in the Quality Payment Program (QPP) means that you always have several years’ information in play at one time.  The score you earned from submitting 2018 data will now be impacting your Medicare reimbursement in 2020; you have just completed your 2019 performance and it’s time to submit your data; and finally, you now have to begin your 2020 performance year.

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. 

Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient.  The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring.  This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.