The Centers for Medicare & Medicaid Services (CMS) recently released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for the 2022 performance year. These scores determine whether a physician will receive a positive, neutral, or negative payment adjustment on Medicare services furnished in 2024. When the final adjustment amounts are released by CMS, we anticipate that the positive payment adjustments some will receive will be higher than years prior. It appears that the number of MIPS eligible clinicians receiving the “exceptional” score is lower than the prior years. As a result, physicians and practices that obtained the 89 points each received a larger share of the $500 million exceptional bonus.
It is also likely that more MIPS eligible clinicians will receive a penalty in 2024, as CMS ceased automatically applying the Extreme and Uncontrollable Circumstances hardship exception due to COVID-19 in 2022 and both the regular and exceptional bonus thresholds were increased. In 2022, MIPS eligible clinicians were required to submit an application for the hardship exception. In addition, the cost measures were no longer reweighted to zero percent of the final scores in 2022.
| Reported Year (Payment Year) | Maximum Payment Adjustment |
|---|---|
| 2018 (2020) | 1.68% |
| 2019 (2021) | 1.79% |
| 2020 (2022) | 1.87% |
| 2021 (2023) | 2.34% |
| 2022 (2024) | +8.25%** |
**This is an estimate based on the information we have received from the American Medical Association, CMS has not released any official statement with final numbers at this time.
Physicians can view review this information and their specific scoring information on the CMS Quality Payment Program (QPP) website using their HCQIS Access Role and Profile (HARP) credentials. For help registering for a HARP account, access the QPP Access User Guide. CMS has also released several resources for more information, including:
- 2022 MIPS Performance Feedback FAQs (PDF, 3MB) – Highlights what performance feedback is, who receives the feedback, and how to access it on the Quality Payment Program website.
- 2022 MIPS Performance Feedback Patient-Level Data Reports Supplement (PDF, 845KB) – Reviews the data included, and answers questions about the downloadable patient-level reports included in performance feedback.
- 2024 MIPS Payment Year Payment Adjustment User Guide (PDF, 710KB) – Reviews information about the calculation and application of MIPS payment adjustments, and answers frequently asked questions.
If a physician believes there was an error in the calculation of their MIPS final score, he or she should request an appeal, which CMS calls a targeted review, by Oct. 9, 2023. Examples of previous targeted review circumstances include the following:
- Data were submitted under the wrong Taxpayer Identification Number (TIN) or National Provider Identifier (NPI).
- Eligibility or special status issues (e.g., a physician has Qualifying APM Participant status and shouldn’t receive a payment adjustment).
- Performance categories weren’t automatically reweighted even though a physician qualified for reweighting due to extreme and uncontrollable circumstances.
CMS generally requires documentation to support a targeted review request, however this requirement varies by circumstance. If the targeted review request is approved and results in a scoring change, CMS will update the final score and associated payment adjustment (if applicable). Please note that targeted review decisions are final and not eligible for further review. For more information about how to request a targeted review, please refer to the 2022 Targeted Review User Guide.
