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MIPS Score Appeal Deadline Coming Up October 21


CMS MIPS 2021

The deadline to appeal 2021 MIPS scores and 2023 MIPS payment adjustments is rapidly approaching. The Centers for Medicaid and Medicare Services (CMS) calls these appeals “targeted reviews”. October 21, 2022 is the last day to submit a targeted review. 

In this blog, we'll review reasons you might want to submit a targeted review as well as how to do it. 

What is a Targeted Review and Why Would I Submit One?

Targeted review is CMS’ term for an appeal of a MIPS score. Each year, the targeted review period is open for the 60 days after Merit-based Incentive Payment System (MIPS) scores are released, the opportunity to submit a "targeted review" closes. During this window, you can review your scores to make sure CMS has calculated your score correctly. If you believe CMS got it right, then great! Your work here is done and you can expect your payment adjustment factor in the relevant payment year to reflect your hard work. 

If you find an issue with CMS' calculation of your score, you'll need to submit a targeted review. Some examples of reasons to submit for a targeted review are: 

  • Your data was submitted under the wrong NPI/TIN.
  • You have a special status that wasn't reflected in a category performance score. 
  • You were approved for a hardship exception, but it wasn't applied.
  • You may have been identified as a Qualifying APM Participant (QP), but you don't belong to an APM. 

While the above reasons are all valid reasons for submission, not all reasons are considered legitimate by CMS. For example, you should not submit a targeted review for reasons like: confusion about scoring policy, not liking your payment adjustment, or disagreeing with benchmarking of measures. 

How to Apply

If you are a MarsdenAdvisors client, contact your Client Success Manager to complete this process for you.

If you are not a MarsdenAdvisors client, submit using the following steps:

  1. Sign in to your QPP account.
  2. Select "Targeted Review" on the left-hand navigation.image-png-Oct-12-2022-06-39-01-78-PM
  3. Add "New Targeted Review" and review the list of valid/invalid reasons for submission. Make sure to select "CONTINUE" after completing this step. 
  4. Select the type of application that reflects how your data was submitted (Individual, Group, APM entity, or Virtual Group) and press "SAVE & CONTINUE".
  5. Enter the submitter details (your contact information, TIN or NPI, etc.)
  6. Review the pre-populated information from the information you shared in step 5. Confirm your Reporting Option (MIPS or APM Performance Pathway) and enter any QPP service desk tickets you might have that are relevant to your targeted review (optional). tr2
  7. You'll need provide contact information and your relationship to the party for whom you are submitting a targeted review. Note: use the same email you use for your QPP account, if possible. 
  8. If you want anyone else to have access to information regarding your targeted review, you can enter their contact information before submitting.
  9. Select the affected Performance Categories for your targeted review. You can also review your performance feedback on this page.
  10. Select the "issue type" that is most relevant to your 2023 payment adjustment factor
    1. Provide a detailed explanation of the issue. You can also add any additional documentation at this step.
    2. Note: if you don't have your supporting documentation available as you are submitting, you can add it after submission by using the "Comments" function for up to 30 days after submission. 
  11. Read the disclosure that summarizes your submission. If it is correct, then click "Certify & Submit". 
  12. Retain documentation of the hardship for at least six years in case of an audit.

If you got this far in the instructions, Congratulations! You have submitted your targeted review. You should get a pop-up message confirming your submission and an email too. You'll be able to monitor the progress of your targeted review anytime on the "Targeted Review Process Summary" page. This page will allow you to track the status of your targeted review, as well as provide documentation (for up to 30 days post-submission) if necessary. 

The length of time a targeted review evaluation varies significantly, so while we can't provide an estimate of when you'll know the outcome of your review, we recommend monitoring its status on the QPP page regularly. If you have questions about your request, click "View Details" and communicate with your reviewer via the comments pane.

Next Steps

  • If you are a MarsdenAdvisors client, contact your Client Success Manager if you have any questions.
  • Share this information with your practice colleagues.
  • Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below. 
  • If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

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

Juliette Walle

Written by Juliette Walle

Juliette Walle is a Health Policy Analyst at the consulting firm MarsdenAdvisors.

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