Posted on August 13, 2020
Your 2019 MIPS performance feedback is now available, which includes your MIPS final scores and payment adjustment information. You should carefully review your reporting results. Any positive or negative payment adjustment will apply to your 2021 Medicare Part B payments for covered professional services. You have until 8pm EST on October 5, 2020 to request a targeted review if you believe an error was made in your 2021 MIPS payment adjustment calculation.
What’s in the 2019 Performance Feedback Report?
It’s important to review your 2019 MIPS performance feedback report which provides information regarding last year’s MIPS reporting results. Your performance feedback will be available for each associated practice at which you were eligible in 2019 and includes your:
- 2019 MIPS final score
- 2021 MIPS payment adjustment
- Final performance category scores and weights for Quality, Promoting Interoperability, Improvement Activities and Cost
- Measure-level performance data and scores
- Any bonus points for complex patients
How Do I Access My 2019 MIPS Performance Feedback Report?
Your MIPS feedback reports are only available from CMS, but MDinteractive can assist you with accessing your reports and interpreting the results. 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 2020 MIPS dashboard, then click "2019 Live QPP Feedback" to view your 2019 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 under the "Estimated Score" column of your dashboard.||Click on the yellow "QPP Performance Feedback" icon under the "Estimated Score" column of your dashboard. |
|Complete the steps.||Complete the steps.|
*A yellow “QPP Performance Feedback” button on your dashboard means the request is pending and you need to take further action to grant MDinteractive access to your reports.
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.
Did the COVID-19 Pandemic Impact My Results?
CMS implemented several new policies in response to the COVID-19 pandemic for the 2019 performance period.
Automatic Extreme and Uncontrollable Circumstances
An automatic extreme and uncontrollable circumstances policy was adopted for all eligible MIPS clinicians who submitted data as individuals. What this means for individual clinicians:
- If you did not report any MIPS data you will automatically receive a neutral payment adjustment in 2021.
- If you only reported 1 performance category you will automatically receive a neutral payment adjustment.
- You will see N/A for every performance category for which you did not submit data. The category will be weighted at 0% for the 2019 performance year (see reweighting policies in the table below).
- The Cost performance category is weighted at 0% (reweighted to Quality in most cases).
Extreme and Uncontrollable Circumstances Application
If you reported 2019 MIPS data, and subsequently submitted and were approved for an extreme and uncontrollable circumstances application (as an individual, group or virtual group) between April 3 and April 30, 2020, CMS will reweight performance categories to 0% and void any previously submitted data. In this circumstance, you would receive a neutral payment adjustment.
How is my Final MIPS Score and Payment Adjustment Calculated?
Your final MIPS score is the sum of your performance category scores and any additional bonus points. Your score will be between 0 and 100 points depending on the amount of data you reported.
Performance Category Weights for Group Reporting
If you reported MIPS as a group, your final MIPS score is based on your group’s performance in 4 MIPS categories, with each performance category having a different weight:
- Quality (45%)
- Promoting Interoperability (25%)
- Improvement Activities (15%)
- Cost (15%)
Performance Category Weights for Individual Reporting
Due to the COVID-19 pandemic, CMS reweighted the categories if you reported MIPS as an individual under the MIPS automatic extreme and uncontrollable circumstances policy:
Performance Category Weights Based on an Approved Extreme and Uncontrollable Circumstances Application
CMS also reweighted the categories if you reported as an individual or a group based on an approved COVID-19 automatic extreme and uncontrollable circumstances application:
Your final score may include additional awarded bonus points for complex patients. If you submitted Quality data in 2019, you could also be eligible for an additional Quality Improvement score.
Truncated and Suppressed Measures
There are a small number of quality measures whose scoring was impacted by:
- Changes to clinical guidelines during the performance period;
- ICD-10-CM code changes during the performance period; and
- Specification changes that were later determined to be substantive.
In some cases,CMS truncated the performance period to 9 months. More often, the measure was suppressed from scoring, meaning the measure was not scored and your quality denominator – the maximum number of points available – was reduced by 10 points. The table below lists all of the impacted measures:
For the 2019 performance period, CMS provided MIPS eligible clinicians who qualify for facility-based measurement the option to use their facility-based scores as an alternate scoring mechanism for the Quality and Cost performance categories. CMS applied the facility-based measurement if the score was higher than the score for performance categories received through another MIPS submission.
How am I scored as a MIPS APM participant?
Under the MIPS APM Scoring Standard, the performance feedback will be based on the APM Entity score and is applicable to all MIPS eligible clinicians within the APM Entity. Final MIPS APM performance feedback and payment adjustment information is available to the APM Entity and to the individual clinicians scored under the APM scoring standard. The individual clinician will need to be approved for the clinician role or be approved as a staff user by the APM Entity. Representatives of participant TINs and practices with clinicians scored under the APM scoring standard will not be able to access the APM Entity’s performance feedback unless they have been approved as a staff user by the APM Entity.
What Does this Mean to Me?
Your final MIPS score determines if you will receive an upward, downward or neutral payment adjustment in 2021. The 2019 MIPS payment adjustments are applied on a claim-by-claim basis to your 2021 Medicare payments made for covered professional services. A final MIPS score of less than 30 points would result in a negative payment adjustment, while a score over 30 points would result in a positive payment adjustment. You are also eligible for an “exceptional performance” bonus if your MIPS score was at or above 75 points. Due to the policies CMS implemented in response to the COVID-19 pandemic, many MIPS eligible clinicians received a final score equal to the performance threshold (30 MIPS points) and a neutral payment adjustment in the 2021 payment year.
The 2021 MIPS payment adjustments vary between -7% and +1.79%. This means a perfect score of 100 MIPS points would result in a positive payment adjustment of +1.79%. Federal law requires CMS to implement MIPS payment adjustments in a budget-neutral manner. Therefore, any positive payment adjustment may be smaller than you expected due to high participation rates in the MIPS program, the large number of scores above the 30 point threshold and policies CMS implemented in response to COVID-19.
Below are some examples of MIPS scores and matching payment adjustments:
|2019 MIPS Score||2021 Payment Adjustment|
What Should I Do If I am Getting a Penalty?
If you don’t agree with your final MIPS score or the payment adjustment you will be receiving from CMS, you have a limited window of time to appeal the decision via a targeted review process. However, CMS is encouraging clinicians to first contact the QPP before submitting a targeted review if possible as it may involve an issue they have already identified as impacting clinicians and groups and are working to resolve it outside of the targeted review process.
A targeted review can be requested from CMS via a QPP account through 8pm EST on October 5th, 2020. It should be requested at the same level as you reported MIPS (individual or group). Once the targeted review deadline passes, you will no longer have a way to dispute your score. This is why it is important to access your reports as soon as they are available.
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.
This CMS guide provides detailed instructions on how to request a targeted view.
Carefully review your 2019 MIPS performance feedback! Your performance feedback can help you determine if improvements are needed for your 2020 MIPS reporting. MDinteractive can assist you with obtaining your performance feedback reports and interpreting the results. If you disagree with your final MIPS score or payment adjustment, you will need to request a targeted review no later than October 5th, 2020.
2019 MIPS Performance Feedback 2021 MIPS Payment Adjustment 2019 MIPS Reporting Result Targeted Review