Overview of the MIPS Program Phases

Phases of MIPS Participation

Participants in the MIPS program follow a structured sequence consisting of three main phases. For MIPS 2021, the reporting phase occurred during the calendar year 2021, with participants receiving their final MIPS scores in August 2022. The final phase involves payment adjustments, which for MIPS 2021 participants will take place in calendar year 2023.

Clarifying MIPS Payment Adjustments

It is important to differentiate between MIPS payment adjustments and MIPS performance reporting. The year 2023 is designated for payment adjustments based on the reporting completed in calendar year 2021. Providers participating in MIPS performance reporting for calendar year 2023 will see their adjustments in calendar year 2025. This blog will provide an overview of the MIPS program, focusing on 2023 as the payment adjustment year.

Payment Adjustment Types in MIPS Reporting

Understanding Data Completeness Requirements

All eligible participants make significant efforts to meet the data completeness requirements for their selected measures. After submitting their Medical Part B claim data, providers receive their MIPS final score. The potential payment adjustment for MIPS 2021 is set at 7%, meaning participants’ performance directly influences their financial outcomes.

Categories of Payment Adjustments

CMS has established three categories of payment adjustments based on participants’ MIPS final scores:

1. **Positive Payment Adjustments**: Providers may receive a maximum of 7% in incentive payments if they achieve a reimbursement rate exceeding 100%.

2. **Neutral Payment Adjustments**: This category applies when an eligible clinician’s reimbursement is exactly 100% for their medical services.

3. **Negative Payment Adjustments**: Providers who achieve less than 100% reimbursement may incur up to a 7% penalty.

Eligibility for MIPS Payment Adjustments in 2023

Criteria for MIPS Participants

Payment adjustments are exclusively available to MIPS participants. For the reporting year 2021, eligible and ineligible participants are clearly outlined.

Determining MIPS Adjustments

The MIPS reporting framework employs a straightforward approach for determining payment adjustments. It involves comparing the MIPS final score against a predetermined performance threshold. For the calendar year 2023, CMS has established a performance threshold of 60 points. Clinicians scoring 60 points or higher will receive a positive payment adjustment.

Impact of Performance Scores

The traditional MIPS framework in 2023 has seen the discontinuation of the exceptional performance bonus, which applied to MIPS reporting for 2021. Providers who scored 85 points or more during that period were eligible for this bonus.

Connecting the 2021 Final Score with 2023 Payment Adjustments

Understanding the Payment Adjustment Scale

The MIPS payment adjustment sheet for 2023 provides comprehensive guidance for providers regarding their adjustments.

– A final score of 0.00 to 15 points results in a -9% adjustment.
– Scoring between 15.01 and 59.99 points leads to adjustments ranging from -9% to 0% on a linear sliding scale.
– Achieving exactly 60.00 points results in neutral adjustments, meaning no penalties or incentives.
– A score between 60.01 and 84.99 points grants a positive payment adjustment greater than 0%, though this is subject to a scaling factor to maintain budget neutrality. The exceptional performance bonus does not apply to scores in this range.
– Clinicians scoring 85 points or more will receive both MIPS incentives and the exceptional performance bonus.

Conclusion

Providers were well-prepared for MIPS reporting in the performance year 2021, having navigated challenges posed by the COVID-19 pandemic. CMS has thoroughly analyzed the data submitted by providers during this period, resulting in reliable MIPS final scores. The payment adjustments for 2023 are directly linked to these scores from the previous year. The MIPS 2023 payment adjustments offer substantial opportunities for providers to secure positive adjustments, while efforts are made to minimize penalties for those who fall below the performance threshold of 60 points.