2017 MIPS Payment Adjustment May Not be What You Expected

July 12th, 2018 by

MIPS feedback reports are in market and healthcare providers are analyzing differences between their “final” scores and what they submitted back in April. Many are seeing vast differences in their final MIPS scores due to mistakes by the QPP system and/or due to the application of calculations and re-weightings that could not be factored in with 100% precision prior to submission.

Clinicians and healthcare organizations that worked with SA Ignite for MIPS submission and performance optimization are currently leveraging the documentation and audit functionality in IgniteMIPS to validate their 2017 submission.

Aside from mistakes which can, and are being reconciled, there are valid reasons why scores and financial payment adjustments may not be what you expected.

Final Calculations

CMS openly points out that some calculations that could not be reflected in preliminary scores are now reflected in final scores, including;

–        Special status for Advancing Care Information (ACI) for hospital-based MIPS eligible clinicians

–        All-Cause Hospital Readmission measure

–        CAHPS for MIPS survey results

–        ACI hardship exception application status

–        Improvement Study Participation Results

–        Performance period benchmarks for Quality measures that didn’t have a historical benchmark

Access the QPP performance feedback report fact sheet here.

Smaller Penalty Pool

Because of the high participation rates and high performance in 2017 MIPS, the budget pool for positive payment adjustments turned out to be smaller than expected.

More specifically, the actual value of the maximum base incentive depends on the actual number of penalized clinicians and their total penalty dollars which, through budget-neutrality, determine the size of the base incentive pool. So, if the actual total penalty dollars are less than CMS previously predicted, the base incentive payment adjustment will be lower.  

In addition, the actual value of the maximum exceptional performance bonus can also vary from what CMS predicted if the number of clinicians above the exceptional threshold of 70 points sharing in the $500M is different from that predicted. If there are more clinicians exceeding 70 points than CMS originally predicted, there will be less exceptional bonus available per clinician, and thereby a smaller exceptional payment adjustment % for any given healthcare organization or clinician. 

Will these factors impact 2018 performance and participation?

In late May, Seema Verma, Administrator for the Centers for Medicare & Medicaid Services (CMS) proudly announced extraordinarily high participation in MIPS for the first performance year – Participation in 2017 exceeded the goal of 90%, reaching 98% among ACOs and 94% among rural practices. See Seema Verma’s May 31st blog.

This high level of participation in 2017 MIPS is a testament to CMS’ ongoing commitment to be responsive to the market, continually receiving comments from the industry and in turn, adjusting the requirements in an attempt to reduce administrative burden.

In its zealous efforts however, CMS may have inadvertently reduced enthusiasm for the MIPS program, appeasing providers with an artificially low performance threshold for 2017 and reducing the performance thresholds for future years as well. Read more in our blog, modifications to MIPS per the 2018 bi-partisan budget act.

The reality of the 2017 MIPS feedback reports may have brought a layer of disillusionment among healthcare organizations and clinicians who scored in the upper 90’s and were looking forward to a meaningful financial reward for their investment in time and resources.

Many of these same providers do still recognize the value in participating in a program like MIPS to move their organizations toward a mindset of value-based care from fee-for-service. MIPS is the spring training for value-based care, as discussed in this recent ABCs of the QPP webinar .

Time will tell whether the results from the first performance year will impact participation and performance in 2018. In the final 2018 MACRA rule, CMS predicts that 74% of providers will earn a MIPS score >70% so it will definitely be more competitive.

Stay tuned for the proposed 2019 MACRA rule which we expect to be published by CMS this summer. Given their activist nature, it will be interesting to see how the program might change for 2019. Save your spot for the next ABCs of the QPP where we will dissect the proposed 2019 rule – date to be determined pending when the rule is published.

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