With a new year comes a few months of straddling three different performance periods for the Centers for Medicare and Medicaid Services’ (CMS) Merit-based Incentive Payment System (MIPS). Here’s a look at what you need to know about the 2018, 2019, and 2020 MIPS performance periods in the new year.
2018 MIPS Performance Period
No, there’s nothing you can do now about the 2018 MIPS performance period, but it is time to feel the effects of how that year went. How you performed in 2018 determines what, if any, payment adjustments you’ll see on your 2020 Medicare Physician Fee Schedule payments.
According to CMS, 98 percent of eligible clinicians participating in MIPS for the 2018 performance period will receive a positive payment adjustment in 2020, a 5 point increase over the 2017 performance year. That means 872,148 clinicians will receive a positive payment adjustment of up to 1.68 percent, and 17,847 will receive a negative adjustment of up to 5 percent.
Theoretically, the positive payment adjustments also could have been as high as 5 percent. However, the MIPS program is mandated as budget neutral. According to CMS, “This means that the funds available for positive payment adjustments are limited to the estimated decrease in payments resulting from the negative payment adjustments.” As long as the vast majority of eligible clinicians are able to participate successfully, the positive adjustments will remain small.
Review your 2018 performance data, which was first released last summer, by going to qpp.cms.gov/login and logging in using your QPP access credentials (download instructions here if you don’t have your credentials – AUTOMATIC DOWNLOAD).
2019 MIPS Performance Period
Though 2019 is over, there are still things to do for the 2019 MIPS performance period.
Confirm Eligibility
According to MIPS guidelines, eligibility criteria changes from one year to the next, and the factors used to determine eligibility are recalculated throughout the year. Even if you’ve already checked before, if your participation status was on the fence, CMS recommends checking your eligibility one last time for 2019. Also, if you already re-checked back in December, you may want to recheck it again, as CMS announced this week that the December updates to the eligibility tool contained some errors.
According to the January 9, 2020, MLN Matters, CMS “discovered and corrected inconsistencies” in the eligibility data. They say the tool can now be used to recheck and confirm your final eligibility status for 2019.
You’ll need your provider NPI in order to check your status, and the results will be provided on the 2019 tab based on any practice or facility tax ID numbers to which you’ve reassigned your Medicare benefits.
Submit Data
The data submission period for the 2019 performance period began January 2, 2020, and remains open until 8:00 p.m. EDT on March 31, 2020.
To submit your data, follow these steps:
- Go to the Quality Payment Program website
- Sign in using your QPP access credentials (download instructions here if you don’t have your credentials – AUTOMATIC DOWNLOAD)
- Submit your MIPS data for the 2019 performance period or review the data reported on your behalf by a third party.
If you elected to report quality measures via Medicare Part B claims, those should have been submitted on your claims throughout the 2019 performance period. You can review preliminary feedback on Part B claims measure data processed to date also by signing in to the Quality Payment Program website using your QPP credentials.
Finally, clinicians in small practices (including those in rural locations), health professional shortage areas, and medically underserved areas can receive no-cost technical assistance with MIPS reporting from selected organizations. Learn more about this support, or connect with your local technical assistance organization, by visiting the Small, Underserved, and Rural Practices page on the Quality Payment Program website.
2020 MIPS Performance Period
Next, prepare for your successful participation in the 2020 MIPS performance year using the following steps.
Confirming Eligibility
Start by confirming your eligibility for 2020 using the same steps outlined above but selecting the 2020 tab. According to CMS, data has been updated to calculate initial 2020 eligibility.
Review New Guidelines
Remember, each performance year has its own set of guidelines. Check to see what’s changed for 2020 by reviewing the CMS’ 2020 Quality Payment Program Final Rule Overview Fact Sheet (automatic download from CMS). You can also find an overview of the 2020 MIPS changes in our recent blog post, “2020 Medicare Physician Fee Schedule: What You Need to Know.” Most importantly, remember that the consequence of not participating at all is a negative 9 percent payment adjustment on 2022 Medicare Physician Fee Schedule payments.
For more information, visit the MIPS page on the Quality Payment Program website.
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