MIPS: Why a “Skating By” Strategy will put Your Practice at Risk in 2021 and Beyond
The stakes increased significantly in the MIPS program beginning in performance year 2019 and even more so into 2021. It has become 15x harder to avoid the penalty than in MIPS program year 1. Now, practices need to perform well in at least two categories to stay neutral or earn a positive adjustment.
Ultimately, the MIPS payment adjustment is budget-neutral, so incentives will always be based on the amount of penalties. A higher number of groups and clinicians being penalized means more money in the penalty pot to pay out in budget-neutral incentives. If few are penalized and/or CMS continues offering flexibilities for penalty avoidance, there will be less money in the pot to pay out in incentives. The exceptional performance bonus is outside of budget neutrality. Practices and clinicians reaching the 85-point threshold or higher in 2020 will earn a much greater revenue increase than those below an 85 MIPS CPS.
A score of 0 to 45 points will result in a penalty in 2020. A score between 45 and 84.99 will result in a scaled payment adjustment between 0% to 0.89%. At a score of 85 or higher, the incentive rate climbs drastically up to an estimated 6.25% with scaling for a perfect 100 MIPS CPS.
You cannot avoid the penalty by submitting minimal data. Submitting for full Improvement Activities (IA) credit will only result in 15 points. This would have avoided the penalty in prior years, however moving forward this will no longer be enough. Practices will need at least 30 more points to avoid penalties in 2022.
The Quality category has a 70% data completeness requirement. Practices that meet the data completeness and report the full 6 measures will earn a minimum of 3 points per measure if they have no performance. This results in 18 achievement points and once re-weighted to the quality category weight of 45% the practice will only earn a Quality CPS of 13.5. If submitted along with full credit for Improvement Activities, that 28.5 CPS would result in a nearly 5% penalty rate to be applied on everything billed in 2022. In order to safely avoid the penalty, a practice should submit for all three categories: Quality, Improvement Activities, and Promoting Interoperability in order to ensure a score above 45 points.
CMS has removed benchmarks during the performance period and changed benchmarks after submission in prior years. By only submitting select categories to report on and/or performing only well enough on a few measures, you are risking a penalty of up to -9% in 2022. As the penalty continues to increase and thresholds become harder to meet in the MIPS program, practices need to have a well-thought-out strategy in place and not chance their financial impact.