CMS Releases 2020 MIPS Performance Feedback and Final Scores

UPDATE: On September 27, 2021, CMS released updates to 2020 MIPS final scores and performance feedback, and 2022 MIPS payment adjustments. CMS is allowing clinicians, groups and APM Entities to request PY 2020 performance category reweighting under the extreme and uncontrollable circumstances policies through the Targeted Review form. Performance category reweighting requests and targeted reviews can both be submitted through the Targeted Review form until November 29, 2021.

The Centers for Medicare and Medicare Services (CMS) recently released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for performance year 2020, along with associated MIPS payment adjustment information for payment year 2022.

The performance threshold for the 2020 MIPS performance year was 45 points. That means MIPS eligible clinicians who scored 45 points will receive a neutral, or 0 percent, payment adjustment, and those scoring above 45 points are eligible for a positive MIPS payment adjustment greater than 0 percent on a sliding scale and multiplied by a scaling factor to preserve budget neutrality. Additionally, clinicians scoring 85 points or above were also eligible for an additional payment adjustment factor for exceptional performance.

On the other end of the scale, MIPS eligible clinicians who scored less than 45 points will receive a negative payment adjustment in the 2022 MIPS payment year. Clinicians with 11.25 points or fewer will receive a -9 percent payment adjustment, and clinicians with points between 11.26 and 44.99 will receive a negative payment adjustment between 0% and -9%, on a sliding scale.

COVID Flexibilities

Because of the ongoing COVID-19 public health emergency, CMS extended the automatic extreme and uncontrollable circumstances (EUC) policy to all individual MIPS eligible clinicians for the 2020 performance year and extended the EUC application deadline for individuals, groups, virtual groups and APM Entities.

As a result, many MIPS eligible clinicians who might otherwise have received a Final Score below the performance threshold (and thus a negative payment adjustment) actually received a MIPS Final Score equal to the performance threshold and a neutral payment adjustment in the 2022 payment year.

The COVID-19 flexibilities included the following for the 2020 performance year:

The complex patient bonus was doubled, allowing eligible clinicians to earn up to 10 bonus points.
The cost performance category was reweighted from 15 percent to 0, and the 15 percent was redistributed to other performance categories.
Individual MIPS eligible clinicians were scored only on performance categories for which data was submitted. All other performance categories were reweighted to 0 percent of their Final Score.
Individual MIPS eligible clinicians who didn’t submit PY 2020 data or who submitted for only one performance category automatically received a neutral payment adjustment in 2022. (This policy did not apply to groups, virtual groups, or APM Entities.)
Groups, virtual groups,and APM entities were able to complete an application to have one or more performance categories reweighted, citing they’ve been impacted by the COVID-19 pandemic.
APM Entities with approved applications were able to override previously submitted data (though this did not apply to groups and virtual groups).

Budget Neutrality

As in previous years, the MIPS program is statutorily required to be budget neutral, which means positive adjustments must be balanced by negative adjustments. To achieve budget neutrality, positive MIPS payment adjustment factors are increased or decreased by an amount called a “scaling factor.” The scaling factor is a number between 0 and 3, and the exact amount depends on the distribution of Final Scores across all MIPS eligible clinicians.

If the scaling factor is less than 1.0, clinicians who earn final scores above the performance threshold will still receive a positive payment adjustment, but the amount will be less than the applicable percent, which is 9 percent for 2022. Likewise, a scaling factor above 1.0 would result in a positive payment adjustment of more than 9 percent for 2022.

A scaling factor also is applied to the additional adjustments for exceptional performance.

Modest Positive Adjustments

According to CMS, the positive payment adjustments for the 2022 payment year will be very modest for several reasons:

A small number of clinicians received a negative payment adjustment because of COVID-19 flexibilities.
High participation rates.
A large percentage of Final Scores that were well above the relatively low performance threshold of 45 points.

“With so many clinicians successfully participating, the distribution of positive adjustments is spread across many more people. This year’s payment adjustment distribution was further affected because clinicians who didn’t submit any data will receive a neutral payment adjustment instead of the maximum negative adjustment,” CMS said in the 2022 Merit-based Incentive Payment System (MIPS) Payment Year Payment Adjustment User Guide {automatic download}.

How to See Your Results

Clinicians can access their 2020 MIPS performance feedback, 2020 final score, and 2022 payment adjustment information by:

Going to cms.gov/login
Logging in using their HCQIS Access Roles and Profile (HARP) system credentials (NOTE: These are the same credentials that allowed you to submit your 2020 MIPS data.)

Request a Targeted Review

Finally, clinicians who believe an error has been made in the calculation of their MIPS payment adjustment factor(s) can request a targeted review through October 1, 2021.

To request a targeted review, access your MIPS final score and performance feedback and request a targeted review by:

Going to the Quality Payment Program website
Logging in using your HCQIS Access Roles and Profile System (HARP) credentials; these are the same credentials that allowed you to submit your MIPS data. Please refer to the QPP Access Guide for additional details.

Learn More

For information about your performance feedback, review the following 2020 MIPS Performance Feedback Resources:

NEW! 2020 Performance Period Benchmarks (ZIP) {automatic download} – Identifies the performance period benchmark results (as available) for measures without a historical benchmark and provides general information about performance period benchmarks.
2020 MIPS Performance Feedback FAQs (PDF) {automatic download} – Highlights what performance feedback httpsis, who receives the feedback, and how to access it on the Quality Payment Program website.
2022 MIPS Payment Year Payment Adjustment User Guide (PDF) {automatic download} – Reviews information about the calculation and application of MIPS payment adjustments, and answers frequently asked questions.