CMS Updates 2020 MIPS Performance Feedback and 2022 MIPS Payment Adjustments
Recently, the Centers for Medicare & Medicaid Services (CMS) released performance feedback for clinicians included in the Merit-based Incentive Payment System (MIPS) for the 2020 performance year (PY).
Along with releasing performance feedback, CMS opened the targeted review period. A targeted review provides the opportunity for clinicians, groups, virtual groups or those participating in certain Alternative Payment Models (APMs) to request review of their MIPS payment adjustment factor(s), if they believe there is an error with their final score and associated MIPS payment adjustment.
The requests that CMS received through PY 2020 targeted review process caused it to take a closer look at a couple of prevailing concerns. The targeted review process worked as intended, as the incoming requests quickly alerted CMS to these issues and allowed it to take immediate action. Based on these requests, CMS reviewed the concerns and identified 2 issues that it needed to correct so that final scores align with its policies. In response, CMS corrected MIPS scoring logic which resulted in changes to performance feedback, including 2020 final scores and 2022 MIPS payment adjustments.
From the onset of QPP, CMS goals have included creating a program that is fully transparent and provides accurate information. CMS believes that the corrections identified below are essential to achieving that goal. CMS will continue to work closely with the clinician community to learn from one another and ensure operational excellence in implementation.
Complex Patient Bonus Correction for Medicare Shared Savings Program ACOs
Specifically, CMS determined that the complex patient bonus was not added to the final scores of Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organizations (ACOs). This issue affected every Shared Savings Program ACO with MIPS-eligible clinicians. In their updated performance feedback Shared Savings Program, ACOs will see up to 10 complex patient bonus points reflected in their performance feedback and added to their final scores, if applicable. (There are approximately 20 ACOs that did not qualify for any complex patient bonus points.) As a reminder, your final score can’t exceed 100 points.
Patient-Reported Outcome Measure Correction
CMS also determined that its system did not recognize patient-reported outcome measures as outcome measures. CMS corrected its scoring logic, which resulted in 2 potential changes to quality performance category scoring for approximately 30,000 MIPS-eligible clinicians:
- Patient-reported outcome measures submitted in addition to another outcome measure became eligible for 2 high priority bonus points. (As a reminder, these bonus points are capped at 10% of your quality denominator.)
- Patient-reported outcome measures became eligible to fulfill the requirement to report an outcome measure.
The majority of affected clinicians will see a modest increase in their quality performance category score and MIPS final score as a result of this correction. However, approximately 4,400 clinicians will see a decrease in their quality performance category score and MIPS final score. This occurred when a lower-scoring patient-reported outcome measure replaced a higher-scoring high priority measure in their top 6 measures, fulfilling the requirement to report an outcome measure. (A high-priority measure is only selected for the top 6 measures in the absence of an available outcome measure.)
Impact to MIPS Payment Adjustments
The statute requires MIPS to be a budget-neutral program, which, means that the projected negative adjustments must be balanced by the projected positive adjustments. As a result of changes to MIPS final scores from these 2 corrections, CMS reassessed the associated MIPS payment adjustments to maintain budget neutrality. Some clinicians that weren’t affected by the issues identified will see slight changes in their payment adjustment due to the reapplication of budget neutrality.
Additional Adjustment for Exceptional Performance
In addition to the standard MIPS payment adjustment, MIPS-eligible clinicians with a final score between 85 and 100 points receive an additional adjustment for exceptional performance. This adjustment is not subject to budget neutrality but is scaled to ensure the appropriate distribution of available funds. When CMS corrected final scores for alignment with its existing policies, more clinicians moved into the exceptional performance pool, causing a slight decrease in the exceptional performance adjustment.
Sign-In to View Updated Feedback
The 2020 final scores and 2022 MIPS Payment Adjustments revisions were made to the performance feedback on the Quality Payment Program (QPP) website on September 27, 2021. CMS encourages you to sign-in to the QPP website as soon as possible to review your performance feedback. If you believe an error still exists with your 2022 MIPS payment adjustment calculation, the targeted review process is available to you.
Targeted Review Extension
To offer additional time for clinicians, groups, virtual groups, APM entities, and their participants to access and review their performance feedback, CMS is extending the targeted review deadline to November 29, 2021 at 8:00pm (ET). You can submit a targeted review by signing in to the QPP website.
CMS also has a number of resources available on its QPP Resource Library to help you understand your performance feedback and the targeted review process, including:
- 2020 MIPS Performance Feedback FAQs (PDF)
- 2020 Targeted Review User Guide (PDF)
- 2020 MIPS Scoring Guide (PDF)
Contact the Quality Payment Program at 1.866.288.8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
PY 2020 Performance Category Reweighting Requests Due to COVID-19 Will Be Accepted Through 11/29/2021
The COVID-19 pandemic continues to impact all clinicians across the United States and territories, and CMS recognizes that not everyone may have been able to submit an Extreme and Uncontrollable Circumstances (EUC) Exception Application for performance year (PY) 2020 before the March 31, 2021 deadline. As part of its ongoing support for clinicians who are on the front lines of this public health emergency (PHE), CMS is allowing clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities to request Merit-based Incentive Payment System (MIPS) performance category reweighting for PY 2020 under CMS EUC policy now through November 29, 2021 at 8 p.m. ET.
There will be a different process for submitting these requests, so please keep reading for more information about:
- Who Can Request Reweighting?
- How Does Performance Category Reweighting Work?
- How Can I Request PY 2020 Performance Category Reweighting?
- What About Automatic EUC Performance Category Reweighting?
Who Can Request Reweighting?
While any clinician, group, virtual group, or APM Entity can request performance category reweighting during this time period due to the COVID-19 PHE, the following types of groups in particular may want to consider submitting a request:
- Small practices that reported Medicare Part B claims measures for the quality performance category but did not report group-level data for other performance categories. Some small practices may not have fully understood the implications of their PY 2020 claims reporting in the context of some of the PY 2019 policies we introduced at the onset of the COVID-19 PHE. As a result, these small practices may wish to request performance category reweighting on behalf of the entire group.
- Virtual groups that were not able to submit an EUC application by the March 31st deadline or their PY 2020 data due to the ongoing COVID-19 PHE. Clinicians that were approved to participate as a virtual group will be scored as a virtual group, regardless of data submission. Some virtual groups with clinicians on the front lines of the COVID-19 PHE may have missed the March 31st deadline for submitting an EUC Exception Application or were unaware that the automatic EUC policy did not apply to their MIPS-eligible clinicians.
In accordance with CMS EUC policies for individuals, groups and virtual groups, CMS will not reweight any performance category for which it has received data. This applies to clinicians who report as individuals and are covered by its automatic EUC policy and to groups and virtual groups that request and receive reweighting. Please note that when fewer than 2 performance categories are scored (for example, one category is weighted at 100% of the final score, and the others are weighted at 0%), the clinician or group will earn a PY 2020 final score equal to the performance threshold and the MIPS-eligible clinician(s) will receive a neutral payment adjustment in payment year 2022, unless a higher final score is available. As a reminder, CMS reweighted the cost performance category to 0% for all clinicians, groups, and virtual groups in PY 2020.
- Example: A small practice received a group score in the quality performance category from reporting Medicare Part B claims measures under our existing policies. The quality performance category cannot be reweighted because CMS received data. However, if the improvement activities and Promoting Interoperability performance categories were approved for reweighting to 0% (and no data was submitted for either of those categories), the quality performance category would be weighted at 100% of the final score. As a result, the group would receive a final score equal to the performance threshold and the MIPS-eligible clinician(s) in the group would receive a neutral payment adjustment in payment year 2022, unless a higher final score is available.
In accordance with CMS EUC policies for APM Entities, data submission for an APM Entity will not override performance category reweighting. If approved, the MIPS-eligible clinicians in the APM Entity will receive a score equal to the performance threshold and a neutral MIPS payment adjustment in the 2022 payment year.
How Can I Request PY 2020 Performance Category Reweighting?
Due to technical limitations, CMS is unable to reopen the 2020 EUC Exception Application form in its systems. Because of these technical limitations, CMS is allowing stakeholders to submit 2020 EUC reweighting requests through the Targeted Review form until November 29, 2021. You can access this form by signing in to qpp.cms.gov. (The EUC Exception Application form currently accessible when you sign in to qpp.cms.gov is for PY 2021 applications only. Do not use the Exception Application form to request PY 2020 reweighting.)
When using the Targeted Review form to submit an EUC reweighting request for PY 2020, you will need to:
- Select the Performance Categories for which you’re requesting reweighting.
- Select “Extreme and uncontrollable circumstances” in the Issue Selection.
- State explicitly in the Description that you’re submitting an EUC application due to the continuing COVID-19 PHE. (In addition, CMS encourages you to reiterate the performance categories for which you are requesting reweighting: quality, improvement activities, and/or Promoting Interoperability.)
Please review 2020 Extreme and Uncontrollable Circumstances: Reweighting Requests Extension Guide (PDF) for step-by-step instructions with screenshots.
What About Automatic EUC Performance Category Reweighting?
CMS applied our automatic EUC policy to all individual MIPS-eligible clinicians for PY 2020. Under this policy, CMS reweighted to 0% any performance category for which data was not submitted, and these performance categories do not contribute to the clinician’s individual final score. However, the automatic EUC policy only applies to those clinicians who were eligible to participate in MIPS as individuals; it does not apply to clinicians who were only eligible to participate as a group or APM Entity, or who elected to participate as a virtual group.
There is no need to request reweighting for PY 2020 for a clinician who was eligible to participate in MIPS as an individual because CMS has already applied reweighting under the automatic EUC policy.
Contact the Quality Payment Program at 1.866.288.8292 or by email at: QPP@cms.hhs.gov, Monday-Friday 8 a.m.–8 p.m. ET. To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. ET.
Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.