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Quality Payment Program (QPP) Support Center

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The Explanation Behind Why Your 2019 MIPS Payment Adjustment Might Be Lower Than You Expected

7/11/2018

On June 29, 2018, the Centers for Medicare & Medicaid Services (CMS) released 2017 final Merit-based Incentive Payment system (MIPS) scores and 2019 payment adjustments. Clinicians had a preliminary MIPS score prior to this date, but no one knew what their payment adjustment would be. CMS could not calculate payment adjustments until everyone's data was reviewed.
Congress mandated that the Quality Payment Program (QPP) be budget neutral, so CMS had to determine how much penalty money would be collected as a result of clinicians that did not report any data. This amount then had to be divided among all of the clinicians that did report.
 
CMS gradually implemented the 2017 performance period, understanding that the QPP was a big change for clinicians. CMS designed a scoring system that would reduce burden and increase flexibility during this transition year. As a result, more clinicians were able to successfully participate. In fact, 91 percent of MIPS eligible clinicians submitted data for the 2017 performance period. With more clinicians participating, the distribution of incentive payments was widely spread. Because the MIPS payment adjustment is required to be budget neutral, a scaling factor is applied to positive 2019 MIPS payment adjustment factors, which may result in a lower adjustment than you may have anticipated. Clinicians that were required to participate and did not, received a 4% payment reduction.

The program and incentives will continue to evolve. If you continue to believe there is an error with your 2017 MIPS final performance score, you may submit a targeted review request as soon as possible. Targeted reviews can be requested until September 30, 2018, but it is strongly recommended that targeted review requests are submitted sooner to ensure that payment adjustments are applied correctly as of January 1, 2019.

The 2019 MIPS Payment Adjustment Fact Sheet highlights how CMS assigns final scores to MIPS eligible clinicians, and how payment adjustment factors are applied for 2019 based on 2017 MIPS final scores.