When the 2019 Merit-Based Incentive Payment System (MIPS) final scores were released, many clinicians raised questions related to their 2021 payment adjustments. Compared with previous years, more clinicians received neutral payments for scores that would have netted positive payments in the first two years of the Quality Payment Program.
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The Centers for Medicare & Medicaid Services (CMS) applies adjustments to Medicare reimbursements for certain services based on individual participation and performance in MIPS. Each MIPS-eligible clinician’s final score forms the basis of their payment. The funding created by negative payment adjustments forms the pool used for positive payment adjustments.
Due to the SARS-CoV-2 pandemic, many eligible clinicians did not submit data for 2019 MIPS. Under the automatic extreme and uncontrollable circumstances policy for 2019 MIPS, CMS assigned these clinicians a neutral payment adjustment instead of the maximum negative payment adjustment. With almost no negative adjustments for 2019 MIPS, the available funding cannot support positive payment adjustments in 2021.
This year, MIPS-eligible clinicians with a final score between 30.01–74.99 points earned a neutral 2021 payment adjustment of 0.00%. MIPS-eligible clinicians with a final score above the performance threshold (75.00 points for the 2019 performance year) are eligible for an additional positive adjustment for exceptional performance. The funds for exceptional performance are not dependent on negative payment adjustments, so clinicians meeting the 75-point threshold will receive a positive payment adjustment.
Although clinicians have to account for these changes in MIPS payment adjustments, the proposed Physician Fee Schedule does include some financial wins for rheumatology professionals, including an expected average 16% payment increase for rheumatologists.
Clinicians who believe an error was made in their scoring and payment can submit a targeted review to CMS until 8 p.m. EDT on Oct. 5, 2020.
To learn more, read the 2021 MIPS Payment Year Payment Adjustment Fact Sheet or contact the CMS QPP Service Center at QPP@cms.hhs.gov.
Allison Plitman, MPA, is the communications specialist for the ACR’s RISE Registry.