Posted on August 14, 2023
The Centers for Medicare & Medicaid Services (CMS) has released the Final Performance Feedback for the 2022 Merit-based Incentive Payment System (MIPS) performance period. It’s essential to check your performance feedback now to view your final MIPS scores and payment adjustment information. If you believe there’s an error in the calculation of your MIPS payment adjustment a targeted review can be requested until 8 p.m. ET on October 9, 2023. This article outlines how to access 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.
What’s Included in My Performance Feedback?
The 2022 MIPS Performance Feedback reflects all of the MIPS data submitted or calculated for an individual clinician, group, or APM Entity participating in MIPS. It includes final MIPS scores and payment adjustment information associated with the 2022 reporting period in the traditional MIPS program or the APM Performance Pathway (APP).
Here’s a breakdown of what’s included in the performance feedback:
- Performance category-level scores and weights
- Bonus points
- Measure-level performance data and scores
- Activity-level scores
- Payment adjustment information
- Patient-level reports
How Do I Access My Performance Feedback?
Clinicians and authorized representatives of practices and APM Entities (including Shared Savings Program Accountable Care Organizations [ACOs]), can access their MIPS Performance Feedback by logging into the Quality Payment Program (QPP) website and clicking “View PY 2022 Final Performance Feedback” on the home page.
If you have an MDinteractive account, we can assist you with accessing your final MIPS score and interpreting the results.
- We have uploaded the Performance Feedback to your MDinteractive account if you previously granted us permission to access your reports. Just click the green “QPP Performance Feedback” icon on your MIPS dashboard then click “2022 QPP Feedback” to view your 2022 feedback 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.
Participants in an APM Entity can view their final score from the 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.
What Makes Up My Final MIPS Score?
The final MIPS score is the sum of the MIPS performance category scores and any points awarded for the complex patient bonus. CMS assigns you the highest possible score based on your Tax Identification Number (TIN) and individual National Provider Identification (NPI) combination if you participated in MIPS in multiple ways (e.g., as an individual clinician and as part of a group). The final score also identifies if the score is based on participation in traditional MIPS or the APP.
MIPS Cost Category
For the 2022 reporting year, the Cost category was worth 30% of your final MIPS score as long as you could be scored on at least one Cost measure. If there are no Cost measure details and no score in your Performance Feedback then the case minimum requirements were not met for any cost measures and the weight for this performance category was reallocated to another category. If you were approved for reweighting in this performance category you can still access measure-level and patient-level feedback if the case minimum was met for at least one Cost measure.
Note that CMS excluded the Simple Pneumonia with Hospitalization measure for all MIPS eligible clinicians. The measure wasn’t included in CMS’s calculation of MIPS any scores under the Cost category for the 2022 performance period.
If you met the case minimum requirements for any administrative claims-based measures or Cost measures, CMS has made available patient-level reports. These reports will provide more insight into your scores for these measures.
Complex Patient Bonus
CMS updated the way it calculates the complex patient bonus beginning with the 2022 performance year. The complex patient bonus is now limited to MIPS eligible clinicians, groups, and APM Entities with at least one risk indicator (either average Hierarchical Condition Categories [HCC] risk score or dual eligibility ratio) at or above the median risk indicator calculated for all MIPS eligible clinicians, groups, and APM Entities from the prior performance year.
An increase of up to 10 percentage points in the Quality performance category could be achieved based on the rate of improvement in quality performance compared to the previous year.
There’s no facility-based scoring available in the 2022 MIPS performance year.
How Was My Payment Adjustment Determined?
The 2022 final MIPS score determines your 2024 MIPS payment adjustment and is based on a sliding scale. The performance threshold for the 2022 MIPS performance year was 75 points. This means your 2022 MIPS final score needs to be 75 points or higher to avoid a negative payment adjustment in the 2024 MIPS payment year.
The MIPS payment adjustments are applied on a claim-by-claim basis to 2024 Medicare payments made for covered professional services. Any payment adjustment is applied to the Medicare paid amount (not the “allowed amount”).
The table below reflects how the 2022 MIPS final scores relate to the 2024 MIPS payment adjustments.
|Final Score||Payment Adjustment|
|0.00 – 18.75 points||Negative MIPS payment adjustment of -9%|
|18.76 – 74.99 points||Negative MIPS payment adjustment, between -9% and 0%, on a linear sliding scale|
|75.00 points (Performance threshold = 75.00 points)||Neutral MIPS payment adjustment (0%)|
|75.01 – 88.99 points||-Positive MIPS payment adjustment, greater than 0% (subject to a scaling factor to preserve budget neutrality)|
-Not eligible for an additional adjustment for exceptional performance
|89.00 – 100.00 points (Additional performance threshold = 89.00 points*)||-Positive MIPS payment adjustment (subject to a scaling factor to preserve budget|
-Eligible for additional adjustment for exceptional performance (subject to a scaling factor to account for available funds)
*The 2022 performance year/2024 payment year is the last year for the additional MIPS payment adjustment for exceptional performance.
The 2024 MIPS payment adjustments vary between -9% and +8.25%. A perfect score of 100 MIPS points would result in a positive payment adjustment of +8.25%. Federal law requires CMS to implement MIPS payment adjustments in a budget-neutral manner.
The table below provides examples of different 2022 MIPS final scores and their estimated payment adjustments:
2022 MIPS Final Score
|2024 Payment Adjustment Estimates|
Did COVID-19 Impact My Results?
For the 2022 performance year, CMS continued to use the Extreme and Uncontrollable Circumstances (EUC) policy to allow MIPS eligible clinicians, groups, and APM Entities to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the COVID-19 public health emergency. Clinicians with an approved EUC for all 4 categories who didn’t submit any data, or who only submitted data in one performance category, will automatically receive a neutral payment adjustment in 2024.
Note that if data was submitted to CMS it overrode performance category reweighting.
How Do I File a Targeted Review?
Carefully review your performance feedback now to determine if a targeted review should be filed. If you don’t agree with your final MIPS score or the payment adjustment information, there is a limited window of time to appeal the decision via a targeted review process.
A targeted review can be requested via a QPP account until 8 p.m. ET on October 9, 2023. It should be requested at the same level as you reported MIPS (individual or group). CMS suggests requesting a targeted review as soon as possible if you identify an error with your MIPS final performance feedback and MIPS payment adjustment factor(s). This will help
ensure that the correct payment adjustment is applied to your claims from the start of the 2024 payment year.
CMS lists the following examples of circumstances for which you may wish to request a
- Your performance data was submitted under the incorrect TIN or NPI.
- You qualified for performance category reweighting because of a special status designation, Promoting Interoperability Hardship Exception, or Extreme and Uncontrollable Circumstances Exception that was incorrectly applied.
As a reminder, once the targeted review deadline passes, you will no longer have a way to dispute your final MIPS score or payment adjustment. This is why it is important to review your performance feedback reports as soon as they are available.
Check your 2022 MIPS final scores and payment adjustments now and file a targeted review before the CMS deadline if you believe an error was made in your payment adjustment calculation. MDinteractive can help you access your performance feedback or interpret the results. MIPS reporting is getting tougher each year, so early planning is critical for MIPS success. If you have not yet started your 2023 MIPS reporting, log in to your MDinteractive account now to complete your 2023 MIPS reporting plans and begin your reporting.
2022 MIPS Reporting 2022 MIPS Performance Feedback 2022 MIPS Scores