Posted on September 15, 2022
The Centers for Medicare & Medicaid Services (CMS) has released the Merit-based Incentive Payment System (MIPS) performance feedback for the 2021 performance year, including MIPS final scores and associated payment adjustments. Clinicians, groups and Alternative Payment Model (APM) Entities that participated in MIPS and believe there’s an error in the calculation of their MIPS payment adjustment can request a targeted review until October 21, 2022 at 8:00pm EST. This article outlines how to check your performance feedback to determine if you are receiving a positive, negative, or neutral payment adjustment and what steps to take if you have any concerns.
Information Available in Your 2021 Performance Feedback
The MIPS performance feedback provides a summary of the data a clinician or group submitted during the 2021 performance year and includes the following information:
- 2021 MIPS final score
- 2023 MIPS payment adjustment
- Measure-level performance data and scores
- Activity-level scores
- Patient-level measure reports (if applicable)
- Performance category-level scores and weights
The MIPS final score is the sum of the performance category scores and any points awarded for the complex patient bonus. The 2021 MIPS final score was compared to performance thresholds to determine whether a clinician or group will receive a positive, negative, or neutral adjustment to their Medicare payments for covered professional services furnished in the 2023 MIPS payment year.
How to Access Your Performance Feedback
Clinicians and authorized representatives of practices and APM Entities (including Shared Savings Program ACOs), can access their performance feedback and payment adjustment information, whether they reported traditional MIPS or the APM Performance Pathway (APP),
by logging into the Quality Payment Program website and clicking "Performance Feedback” on the home page.
MDinteractive can assist clinicians with accessing their final MIPS score and interpreting the results if they have an MDinteractive account.
- If you previously granted us permission to access your reports, we have already uploaded them to your MDinteractive account. Just click the green “QPP Performance Feedback” icon on your MIPS dashboard then click “2021 QPP Feedback” to view your 2021 results now.
- If you have not already given us access, please follow the steps below:
Steps to Grant MDinteractive Permission to Obtain Your Reports:
|New Requests||Pending Requests*|
Log into your MDinteractive account at www.mdinteractive.com
|Log into your MDinteractive account at www.mdinteractive.com|
|Click on the blue "QPP Performance Feedback" icon on your dashboard.||Click on the yellow “QPP Performance Feedback" icon on your dashboard.|
|Complete the steps.||Complete the steps.|
*A yellow “QPP Performance Feedback” button on your dashboard means the request is pending.
Important: If your practice has several users with QPP accounts, only the user with the role “Security Official” will receive an email from QPP to give permission to MDinteractive to access your performance feedback report.
Individual clinicians in the APM Entity can view their MIPS final score and payment adjustment for their APM Entity if they have the clinician role or have been approved as a staff user for the APM Entity. Representatives of Shared Savings Program ACO Participant TINs and practices with clinicians receiving their APM Entity’s final score won’t be able to access the APM Entity’s performance feedback unless they have been approved as a staff user for the APM Entity.
Qualifying APM Participants (QPs) will not receive a MIPS payment adjustment based on these MIPS scores, but will instead receive the 5 percent Advanced APM incentive payment.
How the Payment Adjustment Relates to Your Final Score
Payment adjustments are determined on a sliding scale based on a clinician or group’s final score. The performance threshold for the 2023 MIPS payment year is 60 points. This means that MIPS eligible clinicians with a 2021 MIPS final score of 60 points or higher will avoid a negative payment adjustment in the 2023 MIPS payment year.
The MIPS payment adjustments are applied on a claim-by-claim basis to 2023 Medicare payments made for covered professional services. Any payment adjustment is applied to the Medicare paid amount (not the “allowed amount”).
|2021 Final Score||2023 Payment Adjustment|
|85.00 – 100.00 points|
- Positive MIPS payment adjustment (subject to a scaling factor to preserve budget neutrality)
- Eligible for additional adjustment for exceptional performance (subject to a scaling factor to account for available funds)
|60.01 – 84.99 points|
- Positive MIPS payment adjustment (subject to a scaling factor to preserve budget neutrality)
- Not eligible for additional adjustment for exceptional performance
|60.00 points||Neutral MIPS payment adjustment (0%)|
|15.01 – 59.99 points||Negative MIPS payment adjustment (between 0% and -9%)|
|0 – 15 points||Negative MIPS payment adjustment of -9%|
The 2023 MIPS payment adjustments vary between -9% and +2.33%. A perfect score of 100 MIPS points would result in a positive payment adjustment of +2.33%. Federal law requires CMS to implement MIPS payment adjustments in a budget-neutral manner. Therefore, any positive payment adjustment may be smaller than expected due to high participation rates in the MIPS program, a large number of scores above the 60 point threshold, and policies CMS implemented in response to COVID-19.
The table below provides examples of various 2021 MIPS final scores and their estimated payment adjustments:
|2021 MIPS Final Score ||2023 Payment Adjustment Estimate|
How COVID-19 May Impact Your Results
CMS continued several policies for the 2021 performance period in response to the COVID-19 pandemic.
CMS applied the MIPS automatic extreme and uncontrollable circumstances (EUC) policy to all MIPS eligible clinicians participating in MIPS as individuals for the 2021 performance period.
- Clinicians who didn’t submit any data, or who only submitted data in one performance category, will automatically receive a neutral payment adjustment in 2023.
- Any performance category for which an individual clinician didn’t submit data is weighted at 0% for the 2021 performance year.
CMS also extended the EUC application deadline to March 31, 2022.
- Groups were able to request reweighting of one or more performance categories to 0% (data submission overrode performance category reweighting on a category-by-category basis).
- APM Entities were required to request reweighting of all performance categories and data submission didn’t override reweighting.
CMS reweighted the Cost category from 20% to 0% for the 2021 performance period for all MIPS eligible clinicians regardless of participation as an individual, group, or APM Entity. The 20% Cost performance category weight was redistributed to other performance categories.
When “N/A” is listed in the performance feedback instead of a score for a performance category, this means that the category was reweighted to 0% of your final score.
- MIPS eligible clinicians who submitted some data as individuals will see “N/A” for every performance category for which they didn’t submit data (due to the automatic EUC policy).
- Groups will see “N/A” for every performance category they selected in an approved COVID-19 EUC application, unless data was submitted for that category.
The tables below display the 2021 performance category reweighting policies.
Reweighting for individual clinicians under the 2021 MIPS automatic EUC policy:
Reweighting for groups with an approved EUC application for the 2021 performance year:
Filing a Targeted Review
Clinicians should carefully review their performance feedback now to determine if a targeted review should be filed. Even if a clinician was not MIPS eligible as an individual, but his or her practice reported Medicare Part B claims measures for the Quality performance category in 2021, the clinician could be receiving a penalty because group-level data was not reported for other performance categories to achieve sufficient points to avoid the penalty.
If a clinician doesn't agree with his or her final MIPS score or the payment adjustment information, there is a limited window of time to appeal the decision via a targeted review process. CMS suggests requesting a targeted review as soon as possible if a clinician identifies an error with his or her MIPS final performance feedback and MIPS payment adjustment factor(s). This will help ensure that the correct payment adjustment is applied to the clinician’s claims from the start of the 2023 payment year.
A targeted review can be requested via a QPP account through October 21, 2022 at 8:00pm EST. It should be requested at the same level as the clinician-reported MIPS (individual or group). Once the targeted review deadline passes, clinicians will no longer have a way to dispute their scores. This is why it is important to access performance feedback reports as soon as they are available.
CMS has noted that targeted review decisions are final and not eligible for further review.
Examples of reasons for requesting a targeted review:
- Your performance data was submitted under the incorrect Taxpayer Identification Number (TIN) or National Provider Identifier (NPI).
- You qualified for performance category reweighting, due to a special status designation, Promoting Interoperability hardship exception, or extreme and uncontrollable circumstances exception was incorrectly applied.
- Errors or data quality issues for the measures and activities you submitted.
- Eligibility and special status issues.
- Being erroneously excluded from the APM participation list and not being scored under the APM Scoring Standard.
Clinicians should check their 2021 MIPS scores and payment adjustment information now. A targeted review can be requested by clinicians who believe there’s an error in the calculation of their MIPS payment adjustment factor(s) until October 21, 2022 at 8:00pm EST. MDinteractive's MIPS specialists are standing by for those who need assistance with accessing their final MIPS scores or interpreting the results.
2021 Final MIPS Score 2021 MIPS Payment Adjustment 2021 MIPS Targeted Review