In the Know

CMS Miscalculates 2019 MIPS Payment Adjustments / Extends MIPS Targeted Review Request Deadline 15 Days
October 3, 2018
Alerts
Arnall Golden Gregory LLP

On September 13, 2018, in an update entitled “CMS Updates 2017 MIPS Performance Feedback,” the Centers for Medicare and Medicaid Services (CMS) disclosed that it made errors in the scoring logic used for the merit-based incentive payment system (MIPS). The errors resulted in the agency’s allocation of incorrect payment adjustment amounts to an undisclosed number of clinicians under the 2019 MIPS payment adjustment calculation.

Making way for the error discovery, CMS released performance feedback to individual clinicians, groups, and eligible clinicians in certain Alternative Payment Models (APMs), which provided a comprehensive overview of the MIPS final score, performance category details, and the 2019 payment adjustment calculation. In addition to the feedback, CMS also began a process called “targeted review.” The targeted review process allows for providers to request a review of MIPS payment adjustment factor(s), if it is believed that an error has been made related to the 2019 MIPS payment adjustment calculation. CMS stated that “[t]he requests we received through targeted review caused us to take a closer look at a few prevailing concerns.” CMS looked at the application of the 2017 Advancing Care Information (ACI) and Extreme and Uncontrollable Circumstances hardship exceptions, the awarding of Improvement Activity credit for successful participation in the Improvement Activities (IA) Burden Reduction Study, and the addition of the All-Cause Readmission (ACR) measure to the MIPS final score.

CMS implemented solutions based upon its review, which resulted in changes to the 2017 MIPS final score and the associated 2019 MIPS payment adjustments for those clinicians impacted by the identified issues. Additionally, due to the budget neutrality requirements under the Medicare Access and CHIP Reauthorization Act (MACRA), some clinicians will see changes in their payment adjustments resulting from the reapplication of budget neutrality.

As a result of the errors discovered, CMS extended the request for a targeted review from September 30, 2018 to October 15, 2018 at 8:00 PM EDT.

Should a Clinician Request a Targeted Review?

CMS published examples of circumstances when a clinician may wish to request a targeted review, including, but not limited to:

  • Errors or data quality issues on the measures and activities submitted
  • Eligibility issues (e.g., falling below the low-volume threshold and should not have received a payment adjustment)
  • Being erroneously excluded from the APM participation list and not being scored under APM scoring standard
  • Not being automatically reweighted even though the clinician qualifies for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy

Clinicians can access the MIPS final score and performance feedback and request a targeted review by: 

  • Going to the Quality Payment Program website
  • Logging in using the clinicians Enterprise Identity Management (EIDM) credentials (the same credentials which allowed for the MIPS data submission)

When in doubt, CMS encourages clinicians to contact the Quality Payment Program if they believe that a targeted review of the MIPS payment adjustment is warranted.

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