The Centers for Medicare and Medicaid Services (“CMS”) released the final 2018 performance data for its Quality Payment Program (“QPP”). The data show increases in both clinical participation and success for the 2017 to 2018 time period in the Merit-based Incentive Payment System (“MIPS”) and the Advanced Alternative Payment Model (“APM”) pathways. MIPS was created by the Medicare Access and CHIP Reauthorization Act (“MACRA”) in 2015, and was intended to streamline multiple quality programs, however clinicians found the program “confusing and burdensome,” and the resulting participation was low. CMS has recently been working to improve the system.
Some key findings from the performance data are as follows:
889,995 clinicians participated in MIPS in 2018, which accounts for 98% of all eligible clinicians. This is an increase from a 95% participation rate in 2017.
84% of eligible clinicians will receive an additional adjustment for exceptional performance and an additional 13% will receive a positive payment adjustment, while only 2% will receive a negative payment adjustment. From 2017 to 2018, there was a 5-percentage point increase in the combined number of eligible clinicians receiving exceptional performance adjustments plus positive payment adjustments.
In 2018, 356,353 clinicians participated in MIPS through APMs. This is an increase from 341,220 in 2017.
Large practices fared the best in 2018, with a mean score of 92.32 (out of 100), while rural practices achieved a mean score of 85.99, and small practices had a mean score of 65.69.
In rural practices, 82.91% of clinicians will receive an additional adjustment for exceptional performance, while 14.42% will receive a positive payment adjustment, 0.61% a neutral adjustment and 2.05% a negative payment adjustment.
In small practices, 57.91% of clinicians will receive an additional adjustment for exceptional performance, while 26.00% will receive a positive payment adjustment, 2.89% a neutral adjustment and 13.20% a negative payment adjustment.
Commenting on the clinicians that received negative payment adjustments, CMS Administrator Seema Verma noted that CMS is “committed to supporting these clinicians to reduce reporting complexity and burden, encourage meaningful participation, and improve patient outcomes.” Verma added that CMS “will continue to strengthen program policies that reward the high-quality treatment of patients and increase opportunities for participation.”
CMS also recently announced that they have finalized the MIPS Value Pathways (“MVPs”) proposal in the 2020 Physician Fee Schedule final rule. The MVP is intended to “transform the MIPS program into one that engages clinicians and specialty societies, to craft measures that assess them on what matters most – outcomes.” However, CMS will continue to support the current version of MIPS until the MVP framework is implemented in 2021.
Several changes are coming to the MIPS programs that may reduce these numbers, in 2018 (2020 payments) a minimum MIPS score was 15 points, in 2020 (2022 payments) the minimum MIPS score is 45. For improvement activities under the 2018 program one clinician per practice had to participate in improvement activities, that number changes to 50% in 2020.