DateJuly 3, 2018
 
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QPP Year 1 Update: CMS Informs MIPS Participants of their 2019 Payment Adjustments

The Centers for Medicare & Medicaid Services (CMS) released 2017 Merit-based Incentive Payment System (MIPS) performance feedback. Under the Quality Payment Program (QPP), clinicians participating in MIPS will be subject to payment adjustments based upon performance under four categories: quality, improvement activities, promoting interoperability and cost.

 

The 2017 MIPS performance feedback, reflecting activities in performance year one of the QPP (2017), will indicate if MIPS participants receive a negative, neutral or positive payment adjustment in 2019. Statute requires 2019 MIPS performance adjustments to range from +/-4 percent (with some limited potential for additional bonuses for exceptional performers). Clinicians only needed to submit a single measure on a single patient in 2017 to avoid a negative payment adjustment in 2019.

 

Who Will Receive Performance Feedback?

Individual clinicians (including voluntary submitters), groups, and MIPS APM Entities (those with MIPS eligible clinicians scored under the APM scoring standard) will receive MIPS performance feedback. Clinicians who practice in multiple groups (as identified by a Taxpayer Identification Number, or TIN) will have performance feedback for each group under which they participated in MIPS. Partial Qualifying APM Participants (Partial QPs) will only receive MIPS performance feedback if they elected to participate in MIPS. Qualifying APM Participants (QPs) will not receive MIPS performance feedback.

 

How Do You Access Performance Feedback?

Individual clinicians, groups, Medicare Shared Savings Program participants and Next Generation participants, and their authorized representatives will be able to access performance feedback by logging into qpp.cms.gov with the same EIDM credentials that allowed them to submit and view their data during the submission period.

 

What is Included in the Performance Feedback?

Final MIPS performance feedback will include the following information for each individual clinician, group, or APM Entity: 

  • 2017 final score
  • 2019 MIPS payment adjustment applied to MIPS eligible clinicians (payment adjustments will not be applied to voluntary submitters)
  • Final performance category scores and weights

 

What To Do if You Believe there is an Error in the Final Score?

Clinicians who believe an error has been made in their 2019 MIPS payment adjustment calculation, can request a targeted review until September 30, 2018. The following are examples of circumstances in which a targeted review can be requested: 

  • Errors or data quality issues on the measures and activities you submitted
  • Eligibility issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment)
  • Being erroneously excluded from the APM participation list and not being scored under APM scoring standard
  • Not being automatically reweighted even though you qualify for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy

 

CMS has released a number of documents providing further details:

 


For more information on the Quality Payment Program visit the McDermottPlus MACRA Resource Center or contact Sheila Madhani at 202-204-1459 or smadhani@mcdermottplus.com.