On September 27, 2021, the Centers for Medicare and Medicaid Services (CMS) announced changes to the 2020 MIPS performance feedback and 2022 payment adjustment amounts. In light of these changes, CMS is extending the deadline to file appeals -- known as targeted reviews -- to November 29, 2021 at 8 pm EST. 

Many clinicians will see their total bonus amount go down because the corrections resulted in higher 2020 MIPS scores for those impacted by the errors, thereby increasing the number of clinicians among whom the bonus monies must be split.  

This announcement comes in recognition of two widespread errors CMS found in score calculations during the targeted review process.

Specifically, CMS corrected errors related to the complex patient bonus and patient-reported outcome measures:

• Complex Patient Bonus Correction: Medicare Shared Savings Program (MSSP) ACOs were missing the complex patient bonus, therefore CMS corrected the error by adding the complex patient bonus to their final scores. This affected all MSSP ACOs that had MIPS eligible clinicians.

• Patient-Reported Outcome (PRO) Measure Correction: CMS’s system failed to recognize PRO measures as outcome measures. CMS remedied this error by allowing these measures to serve as the required outcome measure or, as appropriate, by adding two high priority bonus points for these measures in the Quality category.

Impact on Payment Adjustments

• Budget Neutral Bonus: For each performance year, a budget neutral bonus is calculated for MIPS scores that exceed the threshold to avoid a penalty. For this bonus, all of the bonus monies come from the pool of penalty monies. Since the corrections above increased the MIPS Final Scores of those impacted by the errors, those not impacted will see a small decrease in this bonus.
• Exceptional Performance Bonus: This bonus is calculated for all MIPS scores that meet or exceed the exceptional performance threshold (85 points in 2020). As this bonus comes from a fixed pool of money put aside by Congress each year, those who received this bonus and were not impacted by the corrections will see a decrease in this bonus as well. 
• Maximum Total Bonus Amount: Before these changes, the total bonus amount for a 2020 MIPS Final Score of 100 was 2.02%. In the updated feedback released this week by CMS, it is now 1.87%.

Next Steps

• Share this information with your practice colleagues.
• Keep an eye on your email. Your MarsdenAdvisors Client Success Manager is already accessing the QPP reports of our clients and will inform you of any changes within the next week.
• Contact your Client Success Manager if you have any questions. 

If you have any questions on this, let us know!