Performance feedback is now available for the 2018 Merit-Based Incentive Payment System (MIPS) performance year. The feedback presents your final score, including the Cost Category, year-to-year Quality Improvement (if applicable) and the payment adjustment that you will receive. The payment adjustment (positive or negative) will begin January 1, 2020. This information is available for individual clinicians, groups, virtual groups and clinicians participating in the Alternate Payment Models (APM). The performance feedback will also be available for clinicians and groups who voluntarily reported their MIPS data except for the payment adjustment as voluntary reporters are not eligible for it.
This blog focuses on helping you access your Performance Feedback Report and understand it.
You can get to this information through the Quality Payment Program (QPP) website which can be accessed here. You can log in using the same credentials that were used to access the QPP portal for your MIPS data submission or to view your QRUR reports. If you need more information about your access credentials or establishing credentials you can use the reference information here.
EIDM to HARP Transition
CMS has updated the credentialing process. Previously, users created an account and requested access to organizations for the Quality Payment Program through the Enterprise Identity Data Management (EIDM) System. Beginning in December 2018, new users who want to sign in to qpp.cms.gov will create their account in the HCQIS Access Roles and Profile (HARP) system, and all users will request and manage access to organizations by signing in to qpp.cms.gov.
What this means to you
If you have an EIDM account with one of the PV/PQRS roles that lets you sign in to qpp.cms.gov, CMS created a HARP account for you, keeping your EIDM User ID and password. You will still be able to sign in to qpp.cms.gov with your EIDM User ID and password and will have access to the same organizations.
If you didn’t have an EIDM account, you must register for a HARP account by clicking the REGISTER button on qpp.cms.gov as shown below.
Navigating the Performance Feedback Report
Once you gain access to your site, you'll be able to navigate through all the various components that made up your MIPS composite score. First, you will see a high-level view of the practice or practices that you were considered MIPS eligible for and submitted data for the 2018 Performance Year. The information that you will see will detail your overall MIPS composite score as well as the individual performance category scores that contributed to the composite score. Additionally, you will see the MIPS payment adjustment(s) detailed by the standard payment adjustment and the exceptional performance adjustment if you earned one.
The sliding scale that CMS uses to determine the payment adjustment can be reviewed below.
It is important to remember that the 2018 MIPS Performance Year minimum threshold was relatively easy composite score threshold (15 points) and that the CMS payment adjustments must be budget neutral. When a large percent of participating clinicians can meet or exceed the minimum composite score threshold then the payment adjustments will be relatively low. We saw this for the 2017 MIPS Performance Year when the minimum composite threshold was only 3 points. It is important to note that this current 2019 MIPS Performance Year has a composite threshold of 30 points, and an exceptional performance point value of 75 points (up from 70 in 2018). This new threshold of 30 points will be more difficult to meet than the previous years, and therefore it is expected that the payment adjustments will be higher in 2021 for exceptional performers.
You will be able to continue to drill down into your 2018 MIPS information regarding individual clinicians and the details for each performance category (including how CMS determined the Cost Category score for your practice). Another important note is that if you or your group did not meet the case minimums for either cost measure, you'll see a N/A for the Cost final score. The 10 points attributed to the Cost Category in 2018 will be reallocated to Quality Category.
If you would like more information regarding the 2018 MIPS Performance Feedback you can access additional information from CMS here. If you think that your MIPS composite score and/or payment adjustment is different than you anticipated, you should contact the Quality Payment Program or submit a Targeted Review request as soon as possible. You have until September 30, 2019 to request a targeted review. We talked about creating a “Book of Evidence” to be prepared for MIPS audit in our previous blog. In the next blog, we will discuss how to request a Targeted Review and the best practices that will serve you well not only during the review, but also in case of a MIPS audit. Stay tuned.
Need Help with MIPS?
If you would need help with navigating the 2018 MIPS Performance Feedback, we are available to assist you with all your MIPS related needs, right from analysis before submission, submission, and with review and audit after submission.