Your MIPS Feedback questions answered
Thursday, July 12, 2018 | Cherie Kelly-Aduli
Over the past week I have received calls and emails from physicians regarding the 2017 CMS MIPS Feedback Reports released on 6/29/2018. Below is a list of their top questions and my answers. Most of the practices I provide MIPS consulting services to that scored a perfect 100 MIPS total score were pretty disappointed with the 2.02% positive payment adjustment they received. It took a lot of time and money to implement MIPS in our clinics. We thought, at the minimum, we would have seen a positive 4% payment adjustment on our Feedback report. Based on the incentive received this year, many are starting to rethink how much effort they will be putting into MIPS in 2018. In some cases, when I add the cost of MIPS and compare it to the incentive earned, it looks like money might actually be lost. With that in mind, avoiding the penalty looks good right about now.
1.) Who receives MIPS Performance Feedback?
- Individual MIPS eligible clinicians
- APM Entities
2.) When will I receive my MIPS Performance Feedback?
- The 2017 MIPS Performance Feedback Reports are now available in the CMS QPP Portal (qpp.cms.gov). Use your EIDM log in and password to access your results.
3.) What is included in the 2017 CMS MIPS Feedback Report?
- 2017 final score
- 2019 MIPS payment adjustment applied to MIPS eligible clinicians
- Final performance category scores and weight
- Performance details for Cost measures (informational only for 2017; not applicable to MIPS eligible clinicians who are scored under the APM scoring standard).
- Items and services (information about Emergency Department utilization for attributed beneficiaries; this information has no impact on your MIPS score).
4.) What are examples of possible inaccuracies in the Feedback Reports?
- Errors or data quality issues on the measures and activities you submitted
- Eligibility issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment)
- Being erroneously excluded from the APM participation list and not being scored under APM scoring standard
- Not being automatically reweighted even though you qualify for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy
5.) Some of the data on my Feedback Report is incorrect. What should I do next?
- Request a targeted review with CMS.
6.) What is a targeted review?
- A targeted review is a process where MIPS eligible clinicians or groups can request that CMS review the calculation of their 2019 MIPS payment adjustment factor and, as applicable, their additional MIPS payment adjustment factor for exceptional performance.
7.) How do I request a targeted review of my MIPS results?
- Go to the Quality Payment Program website.
- Log in to the QPP Portal with your Enterprise Identity Management (EIDM) user id and password.
8.) What is the deadline for a targeted review?
- You must submit your request no later than September 30, 2018. Supporting documentation must be received by CMS within 30 calendar days of CMS’ initial request for the documentation.
9.) My 2017 MIPS total score was 100. Does that mean I will automatically receive a 4% positive payment adjustment in 2019?
- No, because of the scaling factor used to calculate your score. For additional information on payment adjustments go to the CMS QPP Resource Library and click on the Fact Sheet: 2019 Merit-based Incentive Payment System (MIPS) Payment Adjustments based on 2017 MIPS Final Scores. You can also call the QPP help desk at 1-866-288-8292.
10.) Where can I go to find more information?
Illustration: Lee Sauer
About the Author
Cherie Kelly-Aduli is the CEO of QPP Consulting Group in Mandeville, Louisiana, and a MedAxiom consultant. She has over 16 years of experience in healthcare operations, population health and accountable care. Prior to opening her own firm, Cherie was the Director of Clinical Operations and subsequently Director of Population Health and Accountable Care for the Louisiana Heart Hospital and Medical Group located in Lacombe, Louisiana.
Throughout her career Cherie has been highly successful in efficient practice management, practice adoption of electronic health records, and assisting providers with exceeding standards for patient satisfaction. As payors and patients have transitioned to "pay for value," Cherie has been instrumental in leading private practices and hospital systems to achieve high quality outcomes under the Meaningful Use, PQRS and Value Based Modifier programs; she is now assisting groups with their adoption of the Merit Based Incentive Payment system under MACRA.
To contact, email: firstname.lastname@example.org