UPDATE: CMS Updates 2020 MIPS Performance Feedback and 2022 Payment Adjustments; Appeal Period Extended to November 29, 2021

The Centers for Medicare & Medicare Services (CMS) updated the Merit-based Incentive Payment System (MIPS) performance feedback and final scores for some clinicians following the review of initial targeted review submissions. CMS identified that their system did not recognize patient-reported outcome measures as outcome measures. They corrected the scoring logic which resulted in two potential changes to the quality performance category scoring for approximately 30,000 MIPS Eligible Clinicians. The majority of affected clinicians will see a modest increase in their quality performance category score and MIPS final score as a result of this correction. However, approximately 4,400 clinicians will see a decrease in their quality performance category score and MIPS final score. CMS also determined that the complex patient bonus was not added to the final scores of the Medicare Shared Savings Program Accountable Care Organizations (ACOs).  In their updated performance feedback Shared Savings Program ACOs will see up to 10 complex patient bonus points reflected in their performance feedback and added to their final scores, if applicable.

ECs and groups can view their 2020 MIPS performance feedback, final score, and 2022 payment adjustment. The scores can be accessed on the Quality Payment Program website or visiting qpp.cms.gov/login. Once on these websites, ECs and groups should use their HCQIS Access Roles and Profile (HARP) system credentials. ECs and groups that do not have a HARP account should refer to the Register for a HARP Account and Connect to an Organization documents in the QPP Access User Guide.

MIPS ECs and groups, including APM participants, may request that CMS review the calculation of their MIPS payment adjustment factor(s) through a process called targeted review. If an EC or group believes an error has been made in the calculation of their MIPS payment adjustment factor(s), they may request a targeted review. The deadline to request a targeted review has been extended to November 29, 2021, at 8:00pm (ET).  As a reminder, some examples of previous targeted review circumstances include the following:

• Data was submitted under the wrong Taxpayer Identification Number (TIN) or National Provider Identifier (NPI);
• Eligibility and special status issues (e.g., the EC or group fell below the low-volume threshold and shouldn’t receive a payment adjustment);
• Performance categories weren’t automatically reweighted even though the EC or group qualified for reweighting due to extreme and uncontrollable circumstances.

ECs and groups can request a targeted review by going to the Quality Payment Program website.

CMS generally requires documentation to support a targeted review request, which varies by circumstance. Once submitted, the EC or group will be contacted by a representative with information about any specific documentation required. If the targeted review request is approved and results in a scoring change, CMS will update your final score and/or associated payment adjustment (if applicable), as soon as technically feasible. Targeted review decisions are final and not eligible for further review.