With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Proposed Rule, MIPS participants find themselves wrestling with lingering disappointment from participation in the program in previous years, and resistance to the idea that MIPS will be financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond.
This is the first of a series of blog posts on the 2020 payment adjustment and the 2022 Proposed Rule, that will address this sense of disappointment and show how the future of MIPS will contain much more rigorous program requirements and have greater financial rewards. To see financial and program success, you will need to be prepared to meet the new challenges. We have the guidance you need to succeed in 2021 and beyond.
Today we will focus on the following themes:
- 2020 payment adjustments may be underwhelming,
- Successful reporting in 2021 is not guaranteed
- The 2021 payment adjustment might be bigger than you think
In the charts below, you will see a graphical contrast of expectations and reality surrounding the 2020 payment adjustment, as well as some sample numbers of how this impacts an organization’s Medicare reimbursement.
Expected vs. Actual Payment Adjustments for Medicare
|
Expected and Actual Payment Adjustment Payments for Medicare Part B Revenue Amount |
||
|
Practice Medicare Part B Revenue |
Expected Payment Adjustment Payment |
Actual Payment Adjustment payment |
|
$100,000 |
$9,000 |
$2,200 |
|
$500,000 |
$45,000 |
$11,000 |
|
$1,000,000 |
$90,000 |
$22,000 |
The actual maximum positive payment adjustment in 2020 for a practice that had a perfect score of 100 was 2.2%, which is $22k for a practice with one million dollars of Medicare part B revenue. The expected positive payment adjustment was >9% with a reimbursement of $90k. Hardly a trivial difference.
In a future blog, we will look more closely at the history of the divergence between expected payment adjustments and actual payment adjustments. However, for our purposes today, it is sufficient to attribute much of this actual difference to the public health emergency, COVID-19. Since the Centers for Medicare and Medicaid Services (CMS) waived reporting requirements for all individual clinicians, even those who may have been penalized for non-compliance in another reporting year would not have been penalized in 2020.
Furthermore, all participants affected by COVID-19 who were unable to participate in 2019 or 2020, actually missed out on two years of changing reporting requirements and performance thresholds. For those participants, MIPS participation has changed greatly. These participants will have segued from an easily achievable 15-points in 2018 to a moderately difficult 60-points in 2021, with an expected min/max payment adjustment of 9% that seems unlikely to be mitigated by the ongoing pandemic.
Upcoming major program changes for Program Year 2021:
Performance Threshold increases to 60:
The first genuinely challenging year where providers might meet data completion and submit measures across all performance categories, and still not score well enough to get 60 points. More clinicians are more likely to be penalized.
2021 CMS Quality Measures Benchmark Major Updates:
This update affected all Quality measures. There were over 100 measures that saw over a 20-point change in minimum performance in at least one decile. Tougher deciles will result in lower Quality scores in 2021.No Automatic Reweighting for COVID-19:
Clinicians and groups who were opted out of reporting in 2019 and 2020 are no longer exempted, likely adding to the number of clinicians who can’t make the change from 2018 requirements (15 points) to 2021 requirements (60 points).However, simply focusing on program rules for 2021 masks the true change in difficulty from 2018 to 2021. There are many ways in which CMS has made scoring well in each performance category more difficult, in addition to “raising the bar” by increasing the performance threshold. The following major changes have gone into effect since PY 2018: large practices no longer get points for measures without data completeness, clinicians used to be able to earn 165% of the PI category score, and a sole clinician could satisfy the IA requirements for an entire TIN. There are other, smaller changes, which we may discuss in a future post.
What should we really expect from the PY 2021 payment adjustment (payment year 2023)?
Earlier in this post, we shared that while the expected maximum positive payment adjustment for 2020 was >9%, the actual positive payment adjustment for a score of 100 was 2.2%. Consider our take below on two possible adjustment rates contrasted with the “expected” rate of approximately 9%.
|
Expected Payment Adjustment |
|||
|
Practice Medicare Part B Revenue |
Low |
Midrange Estimate |
Maximum |
|
$100,000 |
$3,500 |
$6,000 |
$9,000 |
|
$500,000 |
$17,500 |
$30,000 |
$45,000 |
|
$1,000,000 |
$35,000 |
$60,000 |
$90,000 |
To maximize the positive payment adjustment for 2021, clinicians should prepare for the change of focus from meeting a minimum point value to competing against other high performers. MIPS performance has been historically high, and exceptional performance is the "new normal." Clinicians and groups who are not "better than average" will find themselves penalized to help incentivize higher-scoring providers. Now is the time to prepare and ensure that you end up on the right side of the performance threshold.
The payment scale remains the same: a maximum penalty of 9%, with available incentive payments based on the size of the penalty pool. With the increases in minimum threshold requirements and fewer opportunities to earn points (decrease in available point-earning measures), it's essential to plan to make sure that you don't end up on the wrong side of the payment adjustment. The Healthmonix approach to value-based care provides MIPS participants with reporting and submission capabilities, a knowledgeable support team and a wealth of resources to help maximize your organization’s performance. Contact us to get a custom performance plan today!
