Early 2020 MIPS data again reveals declining participation

January 28, 2022

According to preliminary 2020 Quality Payment Program (QPP/MIPS) participation data released earlier this week by CMS, just 2% of participants received a negative payment adjustment for poor performance, which continues to drive down bonus payments for strong performers.

Additionally, the number of overall clinicians who participated in the program declined by roughly 4% versus 2019 numbers, dropping from 869,899 to 831,855.

Because the Merit-based Incentive Payment System (MIPS, the traditional reporting path under the QPP umbrella) was designed to be budget neutral, bonuses for strong participants have never reached the lofty heights promised in the program’s early days. While the intent was to use payments withheld as penalties from poor performers to pay participants who qualified for bonuses, the program has consistently set low bars to avoid penalties for various reasons, leaving standard bonuses in most years well below a 2% payment.

While many expected the program would have removed the training wheels for participants by now after first being introduced in 2017, COVID-related flexibilities and waivers granted due to the ongoing Public Health Emergency greatly eased the pathway for participants to opt-out of reporting requirements and associated payment adjustments.

MIPS/QPP bonuses and penalties impact a participant’s Medicare Part B payments two years after a reporting year. That means payment adjustments from the 2020 reporting year are currently being applied throughout 2022.

Key findings include:

  • 89.11% of MIPS eligible clinicians engaged in QPP.
  • The mean score for MIPS eligible clinicians rose from 85.63 in 2019 to 89.41 in 2020, while the median score rose from 92.31 in 2019 to 96.82 in 2020.
  • Overall, MIPS engagement declined from 869,899 clinicians in 2019 to 831,885 clinicians in 2020.
  • MIPS Alternative Payment Model (APM) participation decreased from 416,201 clinicians in 2019 to 398,719 clinicians in 2020.
  • 91% of eligible clinicians received a positive payment adjustment in 2020, with 80.56% of clinicians receiving an exceptional payment adjustment.
  • The number of Qualifying APM Participants (QPs) rose from 195,564 clinicians in 2019 to 237,315 in 2020.

The threshold for a positive score rose from 30.01 in 2019 to 45.01 in 2020, while the threshold for an exceptional payment adjustment rose from 75.00 in 2019 to 85.00 in 2020.

The full participation graphic released by CMS is available to view here:

If you have questions about preparing for 2022 MIPS/QPP reporting, don’t hesitate to reach out to us.

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