Why MIPS Bonuses Are Going Down Even Further

The Centers for Medicare and Medicaid Services (CMS) announced the results of the 2017 Merit-based Incentive Payment System (MIPS) reporting period a couple of months ago.¹ At that time, the CMS stated that 91 percent of eligible professionals participated in the program. This high rate of participation meant only 9 percent of eligible professionals will be penalized. 

Given the reported high rate of participation, and the budget neutrality of the system, there is a small amount of penalty money to distribute to a large number of those who earned bonus money. This resulted in a 2017 MIPS score of 100 equaling a 2019 fee schedule adjustment of only +2.02 percent.

However, on September 13, 2018, CMS announced there had been “errors in the scoring logic” and that more people were penalized than should have been.¹ By rescinding these penalties, there is even less penalty money, which, in turn, means there is even less bonus money.

After correcting the errors, CMS updated performance feedback on the Quality Payment Program (QPP) website. If you logged in to view your results prior to September 13, 2018, they are different now. Whereas a 2017 score of 100 MIPS points resulted in a 2019 fee schedule adjustment of +2.02 percent prior to this change, it now results in only a +1.88 percent adjustment in 2019. Some adjustments as of September 13, 2018 were as follows:

2017 MIPS points       2019 Fee Schedule Adjustment

0                                  -4 percent

3                                  Neutral

15                                +0.04 percent

40                                +0.11 percent

100                              +1.88 percent

These 2019 adjustments may change again. After identifying their errors, CMS extended the targeted review deadline to 8 p.m. EST, October 15, 2018. With more reviews, CMS may find more errors. If CMS finds more errors and rescinds more penalties, there will be less penalty money, which would mean there will be less bonus money. The aforementioned adjustments could go down even further. Stay tuned!

To check your currently planned 2019 fee schedule adjustment, visit www.qpp.cms.gov and sign in.

Dr. Lehrman is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Fellow of the American Academy of Podiatric Practice Management (AAPPM). Follow him on Twitter @DrLehrman

Reference

1. Centers for Medicare and Medicaid Services. CMS Updates 2017 Performance Feedback. Available at  https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2017-MIPS-Performance-Feedback-Statement.pdf .