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On October 27, the Centers for Medicare & Medicaid Services released preliminary participation numbers and payment adjustments in its Quality Payment Program. For most participants in the Merit-based Incentive Payment System (MIPS) pathway, adjustments to Medicare payments next year will range from 0.09% to 1.79%. Of note, no MIPS participants will receive a negative adjustment in 2021.
The published CMS blog post and infographic describe how COVID-19 and the CMS Extreme and Uncontrollable Circumstances policy affected this budget neutral program. Budget neutrality allows for those groups who either did not report MIPS or who did not score above the minimum scoring threshold to be penalized by 7% in 2021. The money collected from their negative adjustment would have been redistributed to those individuals and groups scoring above the scoring threshold. Because CMS extended the Extreme and Uncontrollable Circumstances policy to those eligible clinicians who had not submitted data in 2019 and to allow reweighting of MIPS performance categories affected by COVID, CMS ended up with no individuals or groups being penalized in 2019.
This CMS policy resulted in individuals and groups scoring between 30.01 and 74.99% in 2019 to receive a 0.00% payment adjustment in 2019. CMS Administrator Seema Verma wrote, “Though this may be disappointing, it’s critical that we support every clinician so they can focus on what’s most important during the COVID-19 pandemic, caring for patients. Some may question whether participating in the Quality Payment Program has been worth the investment given lower positive payment adjustments. We urge clinicians to continue on this journey to value-based care with us.”
CMS expects payment adjustments for those individuals and groups who qualified for the exceptional performance bonus by receiving MIPS scores above 75.00% to receive a bonus between 0.09% and 1.79%. That additional positive payment adjustment is not subject to budget neutrality, but CMS applies a scaling factor to account for available funds.
Final regulatory updates to the 2021 Quality Payment Program performance year are expected to be released by CMS in December 2020.
