Your 2022 MIPS payment adjustment may have changed. Here’s why

The Centers for Medicare & Medicaid Services (CMS) has identified two issues that prompted it to correct its Merit-based Incentive Payment System (MIPS) scoring, resulting in changes to 2020 final scores and 2022 payment adjustments.

CMS recently opened its targeted review process for physicians and other MIPS participants who believe there’s an error with their 2020 performance score and associated 2022 payment adjustment. Based on the targeted review requests it received, the agency identified two things that needed to be updated in its scoring procedures. First, CMS determined the complex patient bonus wasn’t added to the final scores of Medicare Shared Savings Program accountable care organizations (ACOs). This issue affected every Medicare Shared Savings Program ACO with MIPS-eligible clinicians. Those ACOs will see up to 10 complex patient bonus points reflected in their updated performance feedback and added to their final scores, if applicable. (Approximately 20 ACOs didn’t qualify for any complex patient bonus points.)

Second, CMS determined its system didn’t recognize patient-reported outcome measures. CMS corrected its scoring logic related to this, resulting in two potential changes to quality performance category scoring for approximately 30,000 MIPS-eligible clinicians:

• Patient-reported outcome measures submitted in addition to another outcome measure became eligible for two high priority bonus points.
• Patient-reported outcome measures became eligible to fulfill the requirement to report an outcome measure.

Most affected clinicians will see a modest increase in their quality performance category score and MIPS final score because of this correction. However, about 4,400 will see a decrease because a lower-scoring patient-reported outcome measure replaced a higher-scoring high priority measure in their top six measures.

The law requires MIPS to be budget neutral, which means projected negative adjustments must be balanced by projected positive adjustments. Because of changes to MIPS final scores from these two corrections, CMS reassessed the associated MIPS payment adjustments to maintain budget neutrality. Because of this, some clinicians who weren't affected by the identified issues will still see slight changes in their payment adjustment. 

MIPS-eligible clinicians with a final score between 85 and 100 points receive an additional adjustment for exceptional performance. This adjustment isn’t subject to budget neutrality, but is scaled to ensure the appropriate distribution of available funds. When CMS corrected final scores for alignment with its existing policies, more clinicians moved into the exceptional performance pool, causing a slight decrease in the exceptional performance adjustment.

The 2020 MIPS final scores and 2022 payment adjustments are available on the Quality Payment Program (QPP) website. You may sign into the QPP website to review your performance feedback or submit a targeted review request if you believe an error still exists with your 2020 MIPS performance score or corresponding 2022 payment adjustment. CMS has extended the targeted review deadline to 8 p.m. (ET) Nov. 29.

The QPP Resource Library has resources to help you understand your performance feedback and the targeted review process, including:

• 2020 MIPS Performance Feedback Frequently Asked Questions
• 2020 Targeted Review User Guide
• 2020 MIPS Scoring Guide

If you have questions, please contact the QPP at 1-866-288-8292 or QPP@cms.hhs.gov. To receive assistance more quickly, call during non-peak hours: before 10 a.m. and after 2 p.m. (ET). Individuals who are hearing impaired can dial 711 to be connected to a TRS communications assistant.

— Kent Moore, Senior Strategist for Physician Payment