Once again the first few months of the new year require physicians and other healthcare providers to bridge three different program years of 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 2019, 2020, and 2021 MIPS performance periods in the new year.
2019 MIPS Performance Period
How they performed in 2019 determines what, if any, payment adjustments providers will see on their 2021 Medicare Physician Fee Schedule payments.
According to CMS, more than 97 percent of MIPS eligible clinicians “engaged with the program by submitting some data at the individual, group, virtual group, or Alternative Payment Model (APM) Entity level for 2019.”
Of those that engaged with the program, 98 percent of MIPS eligible clinicians earned more than 30 points and were considered successful reporters. Typically, these successful participants would earn positive payment adjustment distributed in a budget neutral way from the funds withheld from those who failed to successfully participate in the program.
However, because of the public health emergency related to COVID-19, CMS provided extensive Extreme and Uncontrollable Circumstances Exceptions “to all individual MIPS eligible clinicians for the 2019 performance year who had not submitted data to CMS” and reopened the 2019 Extreme and Uncontrollable Circumstances application “to allow clinicians, groups, and virtual groups to request reweighting of the MIPS performance categories to 0 percent.”
As a result, CMS reported in an October blog post that has now been archived that no eligible providers who engaged with the program are receiving a negative payment adjustment for 2021 as a result of the MIPS program. With less than 3 percent of eligible providers not engaging, and those presumably receiving the maximum negative payment of adjustment of -7 percent, CMS has a very small pool of money to distribute among those who successfully participated in the program.
In fact, positive payment adjustments are distributed first to those who had the highest scores, with diminishing amounts to those with smaller successful scores. The program also has a small amount of Congressionally designated funds for “exceptional performers” of the program, which for 2019 was anyone who scored above 75 points. According to CMS, 86 percent of eligible providers who engaged with the program earned a final score of 75.00 points or more. All positive payment adjustments will be directed toward those providers, who will receive a positive payment adjustment of up to 1.79 percent on their 2021 Medicare payments.
“Some clinicians may see lower than expected positive payment adjustments,” wrote Seema Verma, former CMS Administrator. “This is because the Quality Payment Program is required by law to be budget neutral, and more clinicians who may have faced maximum negative adjustments qualified for reporting exceptions under the MIPS Extreme and Uncontrollable Circumstances policy. As a result, there is a smaller pool of dollars from negative payment adjustments that can be redistributed and used for the positive payment adjustments.”
Providers can review their 2019 performance data, which was first released last summer, by going to qpp.cms.gov/login and logging in using your QPP access credentials.
2020 MIPS Performance Period
Though 2020 is over, there are still things to do for the 2020 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 2020.
You’ll need your provider NPI in order to check your status, and the results will be provided on the 2020 tab based on any practice or facility tax ID numbers to which you’ve reassigned your Medicare benefits.
Submit a COVID-19-Related MIPS Extreme and Uncontrollable Circumstances Application
CMS has extended the deadline for COVID-19-related 2020 MIPS Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021. Clinicians, groups, and virtual groups who believe they are eligible for this exception may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will be added to the QPP Participation Status Tool.
CMS has acknowledged that any data submitted for an individual, group, or virtual group (before or after an application has been approved) will be scored, however.
Submit Data
The data submission period for the 2020 performance period began January 4, 2021, and remains open until 8:00 p.m. EDT on March 31, 2021.
To submit data, providers should follow these steps:
- Go to the Quality Payment Program website
- Sign in using your QPP access credentials
- Submit your MIPS data for the 2020 performance period or review the data reported on your behalf by a third party.
If a provider elected to report quality measures via Medicare Part B claims, those should have been submitted on your claims throughout the 2020 performance period. However, providers have until March 1, 2021, to submit remaining 2020 claims for the Quality performance category.
2021 MIPS Performance Period
Finally, prepare for your successful participation in the 2021 MIPS performance year using the following steps.
Confirming Eligibility
Start by confirming your eligibility for 2021 using the same steps outlined above but selecting the 2021 tab. According to CMS, data has been updated to calculate initial 2021 eligibility.
To be eligible to participate in MIPS in 2021, you must:
- Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS); AND
- Furnish covered professional services to more than 200 Medicare Part B beneficiaries; AND
- Provide more than 200 covered professional services under the PFS.
Review New Guidelines
Remember, each performance year has its own set of guidelines. Check to see what’s changed for 2021 by reviewing CMS’ 2021 Quality Payment Program Fact Sheet and Resources {ZIP FILE download}. You can also find an overview of the 2021 MIPS changes in our recent blog post 2021 Medicare Physician Fee Schedule Final Rule: What You Need to Know.
Most importantly, remember that the consequence of not participating at all is a negative 9 percent payment adjustment on 2023 Medicare Physician Fee Schedule payments.
For more information, visit the MIPS page on the Quality Payment Program website.
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