Eligible providers who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can now review their performance reports, according to the Centers for Medicare and Medicaid Services (CMS), and 2017 MIPS participants can expect to see some performance information on the Physician Compare website.
Increases in 2018 MIPS Participation
The MIPS participation rate among eligible providers rose to 98 percent for 2018, up three percent from 2017, according to a blog post published by CMS. However, the total number of MIPS participants fell from 1,057,824 in 2017 to 916,058 in 2018. Of that total, 559,230 eligible clinicians participated in MIPS (down form 716,603 in 2017), and 356,828 participated in MIPS Alternative Payment Models (APMs) (up from 341,220 in 2017).
Part of the decline in total participants may be a result of eligibility guidelines, which changed in 2018. Increases in the Medicare patient count and Medicare Part B allowed charges that determined who was eligible meant that fewer clinicians in small practices were required to participate. Of note, however, was that more clinicians in small practices did choose to participate, with nearly 90 percent of clinicians in small practices participating in 2018, an increase from 81 percent in 2017.
Another factor contributing to a decline in the total participants is the increase in the number of Qualifying Advanced Payment Model Participants, which nearly doubled from 99,076 clinicians in 2017 to 183,306 in 2018.
Of those who participated in the MIPS program in 2018, 97.63 percent exceeded the performance threshold to qualify for a positive payment adjustment, up from 93.12 percent. Only 1.95 percent fell below the performance threshold to earn a negative payment adjustment.
Skeptical of Success
While CMS is hailing these numbers as a success for the Quality Payment Program (QPP), some providers are skeptical. For one, MIPS payment adjustments are budget neutral, which means the fewer clinicians who earn negative adjustments, the smaller the pool of money to spread among those earning positive adjustments. In 2017, the highest earners received a mere 1.88 percent positive adjustment on their 2019 Medicare payments. With an even greater percent of participants exceeding the performance threshold for 2018, the positive payment adjustments are likely to be smaller in 2020.
As well, the costs of participating in MIPS continue to go up. For instance, more and more clinician and/or staff time is required to complete documentation and measure reporting in the various performance categories. As well, starting in 2019, clinicians were required to use the 2015 Edition CEHRT to comply with the Promoting Interoperability (PI) performance category, which meant significant technology investments for some practices. And even if clinicians were exempt from reporting the PI category, many had to pay to use a Qualified Registry or a Qualified Clinical Data Registry to report quality measures.
On the other hand, not participating in MIPS in 2019 means an automatic 7 percent negative adjustment in 2021. That percentage goes up to 9 percent in subsequent years.
Find Out Your 2018 Participation Information
For now, providers can see their specific MIPS participation information, including how they fared with the performance criteria, by going to qpp.cms.gov/login and logging in using their HCQIS Access Roles and Profile (HARP) system credentials (the same credentials that allowed them to submit their 2018 MIPS data). For information about specific performance feedback, CMS has developed a set of frequently asked questions (FAQs) (PDF DOWNLOAD). Providers who believe an error has been made in calculating their 2020 MIPS payment adjustment have until September 30, 2019, to request a targeted review (PDF DOWNLOAD). To do so, they can also log in to the Quality Payment Program website with their HARP system credentials, just as they did to access their performance information. CMS may require clinicians to submit additional documentation to support the targeted review request.
2017 MIPS Data in Physician Compare
Meanwhile, as clinicians are reviewing their 2018 MIPS performance reports, CMS also announced that 2017 QPP performance information is now available on the Physician Compare website. Specifically, the following 2017 Quality Payment Program performance information has been added to Physician Compare profile pages:
- 12 MIPS quality measures reported by groups and displayed as measure-level star ratings on group profile pages;
- 8 Consumer Assessment for Healthcare Provider and Systems (CAHPS) for MIPS summary survey measures displayed as top-box percent performance scores on group profile pages;
- 6 Qualified Clinical Data Registry (QCDR) quality measures reported by groups and displayed as percent performance scores on group profile pages;
- 11 QCDR quality measures reported by individual clinicians and displayed as percent performance scores on individual clinician profile pages.
For more information about the 2018 MIPS performance data released to participating clinicians or the 2017 MIPS performance data added to Physician Compare, check out the following resources:
- CMS Blog post: “Quality Payment Program Releases 2017 Physician Compare Data and Sees Increases in Clinician Participation Rates and Success for 2018”
- Quality Payment Program Participation in 2018: Results At-A-Glance (PDF DOWNLOAD)
- 2018 MIPS Performance Feedback FAQs (PDF DOWNLOAD)
- “Participation in APMs, MIPS climbed significantly in 2018” from Healthcare Dive
- 2018 Targeted Review Fact Sheet (PDF DOWNLOAD)
- 2018 Targeted Review FAQs (PDF DOWNLOAD)
- Physician Compare Initiative page
- Quality Payment Program and Physician Compare Factsheet: What You Need to Know for Performance Year 2017
- Group Performance Information on Physician Compare: Performance Year 2017
- Clinician Performance Information on Physician Compare: Performance Year 2017
- Accountable Care Organization (ACO) Performance Information on Physician Compare: Performance Year 2017
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