On Tuesday, CMS unveiled its analysis of 2019 Quality Payment Program (QPP) and Merit-based Incentive Payment System (MIPS) participation, again revealing another year of strong buy-in from clinicians that resulted in minuscule bonuses for their trouble.
Of the 954,614 clinicians CMS said will receive a 2021 payment adjustment based on their 2019 performance, just .32% earned a final score below the 30-point performance threshold, meaning they will receive a negative Medicare Part B payment adjustment beginning next year. Since MIPS is a budget neutral program designed to pay bonuses to strong performers through payment penalties withheld from low-performing participants, CMS said those who scored between 30.1 and 74.99 points will receive a neutral payment adjustment next year.
Small bonuses of up to 1.79% were achieved by 84% of the overall participants because they achieved what CMS deems an “exceptional” score of 75 to 100 points. The exceptional bonus pool is a separate allocation that is not impacted by the program’s budget neutrality requirements.
However, for those concerned that the larger bonuses CMS initially highlighted when the program was first introduced in 2017 will never come to fruition, there are a few statistics and changes that point to successful reporting becoming more difficult, which should in turn increase the penalty pool.
First, the “performance” (penalty-avoidance) threshold continues to rise. For 2020 reporting, clinicians must earn at least 45 points to avoid a penalty. That threshold jumps again to 50 points for 2021 reporting. As always, a performance year impacts Medicare Part B payments two years in advance.
Secondly, both the mean and median scores out of 100 points dropped from 2018 to 2019. While the decreases were small (86.96 to 85.55 and 99.63 to 92.31, respectively) this could indicate some groups will see a drop off in performance as the program continues to evolve.
Also keep in mind that CMS is again offering those impacted by the COVID-19 Public Health Emergency the opportunity to request an exemption from 2020 MIPS reporting, which could again result in a large number of neutral payments if those exemptions are widely utilized.