MIPS Participation Drops per Preliminary Report
By Emma Freer

Fewer clinicians participated in Medicare’s Quality Payment Program (QPP) in 2020, and fewer participants earned incentive payments compared with 2019, according to preliminary data recently released by the Centers for Medicare & Medicaid Services (CMS).

Texas Medical Association staff say two C’s – complexity and COVID-19 – are probably big reasons why.

Clinicians can participate in QPP through either the Merit-Based Incentive Payment System (MIPS) or an advanced alternative payment model. During the 2020 performance year, 89.11% of MIPS-eligible clinicians participated in QPP, more than eight percentage points less than in 2019, according to CMS. This difference was even starker among MIPS-eligible clinicians in small practices, 77.10% of whom participated in QPP during 2020, a drop of nearly 23 percentage points from 2019.

Robert Bennett, TMA’s vice president of medical economics, says this drop-off is likely due to multiple factors, including the ongoing pandemic and the complicated nature of the program. He also raised concerns about CMS’ reporting process, given the lag time between the end of 2020 and the release of QPP data for that year. CMS made 2020 MIPS scores and feedback visible to participants in August 2021.

“If we’re really going to improve quality, this feedback should be timely and clinically actionable,” he said.

The share of clinicians earning an incentive payment remained high despite the program’s scoring thresholds increasing in 2020. Participants needed to score more than 45 points to receive an incentive payment for the 2020 performance year and at least 85 points to receive an additional payment for exceptional performance, up from the 2019 thresholds of 30 and 75 points.

The vast majority of participants – 91% – earned an incentive payment, which they’ll see later this year due to a two-year lag between performance year and payment year. That’s a slight decrease from the 96% who earned an incentive payment for 2019.

According to CMS:

• 10% of 2020 participants will receive an incentive payment of up to 0.1% of their practice’s Medicare billings;
• 81% will receive an additional payment of up to 1.87% for exceptional performance;
• 7% will receive no payment adjustment; and
• 2% will receive a penalty of up to 9%, up from 0% in 2019.

David Brigati, MD, an orthopedic surgeon in Fort Worth and member of TMA’s Council on Health Care Quality, takes an optimistic view of these data. Although he was concerned about how small and rural practices would fare during 2020, given the financial toll of the pandemic and the administrative burden of participating in MIPS, he was heartened to learn only 2% of clinicians will receive penalties this year.

This is likely due to certain pandemic flexibilities, including MIPS’ extreme and uncontrollable circumstances policy, under which individual physicians qualified for a hardship exemption that allows them to avoid penalties entirely.

(MIPS-eligible clinicians reporting as individuals who submit data for the 2021 performance year by March 31 will automatically receive no incentive payment or penalty, unless they have a higher score from group or alternative payment model entity participation.)

Several lawmakers are trying to see that CMS continues offering help to small practices that might struggle with QPP. Four members of Congress, including U.S. Rep. Michael Burgess, MD (R-Lewisville), the senior physician representing Texas, introduced the Small Practice, Underserved, and Rural Support Program Extension Act on Feb. 2. If passed, the bill would reauthorize a CMS technical assistance program that helps small practices in rural and underserved areas complete their QPP reporting requirements. As of now, it’s set to expire on Feb. 15.

“Our health care heroes have put it all on the line over the duration of this pandemic,” Dr. Burgess said in a Feb. 2 statement. “We have a responsibility to support them in every way we can.”