CMS releases MIPS physician performance report

MIPS Update

The Centers for Medicare and Medicaid Services (CMS) recently released a report on performance by physicians under the Merit-based Incentive Payments System (MIPS). The good news is that 98% of those eligible will receive a positive adjustment in 2020 based on performance in 2018. The bad news is that the adjustment ranges from only 0.2% to 1.68%. This is largely due to budget neutrality in the law which requires that positive payment adjustments be limited to the estimated decrease in payments from those receiving negative adjustments. However, only 2% of MIPS participants will receive negative adjustments; 13% will receive a positive adjustment of no more than 0.2%. And 84% who fall into the “exceptional performance” category receive a maximum adjustment of 1.68%. It is unlikely that the positive adjustments will increase in future years.

Many allergy practices are exempt from MIPS reporting because they qualify for the low volume exception. Under that exception, if annual Medicare-allowed charges are $90,000 or less, or if a physician has 200 or fewer Medicare patients, they are exempt from MIPS and will not be penalized for failing to report MIPS measures.

The most effective way to receive positive adjustments from Medicare is to participate in an Advanced Alternative Payment Model (AAPM). This could entitle one to a bonus payment of 5%. However, CMS has not approved any of the APMs put forth by the physician community. The only AAPMs that have been approved by CMS are certain medical home models, accountable care organizations, and CMS demonstration projects, such as the bundled care for payment initiative. While there are a few AAPMs that target certain specialties/diseases (e.g., end-stage renal disease, oncology, joint replacement), none focus on allergy care.

Many in the physician community feel frustrated with the MIPS program, which is considered administratively burdensome with very little reward. At the same time, CMS has been reluctant to approve new specialty-focused AAPMs. The College has submitted a proposal for an APM on asthma care to the Physician-Focused Payment Model Technical Advisory Committee. It is currently undergoing review.

How to find MIPS adjustments on claim remits

On 2020 Part B claim remits, positive MIPS payment adjustments are displayed on a remittance advice (RA) as:

• CARC 144: Incentive adjustment, e.g., preferred product/service.
• RARC N807: Payment adjustment based on MIPS.
• Group Code CO, which is used when a contractual agreement between the payer and payee, or a regulatory requirement, resulted in an adjustment.

Negative MIPS payment adjustments are displayed on RAs as:

• CARC 237: Legislated/Regulatory Penalty.
• RARC N807: Payment adjustment based on MIPS.
• Group Code CO.

For additional information on MIPS payment adjustments, view CMS’ 2020 Merit-based Incentive Payment System (MIPS) Payment Adjustment Fact Sheet.