Reporting, Scoring, & Financial Impacts
How is MIPS Reported?
Group or Individual?
Providers can elect to report MIPS as individuals or as a group (two or more providers that bill under the same tax identification number). Providers that report as a group will receive a Composite Performance Score based on the performance of the group as a whole.
The election of individual or group reporting must be the same for all four performance categories.
To meet MIPS reporting requirements in 2017, CMS requires that providers submit data and/or attest to performance from a contiguous, self-selected 90-day period within the calendar year.
Providers can choose a reporting period that is longer than 90 days, but it may be disadvantageous to do so, since the Composite Performance Score is determined by CMS using only the data submitted. Most providers are expected to select a 90-day reporting period.
Critically, the reporting period does not need to be the same for all the performance categories. A provider may choose one 90-day period to collect and report Quality measures, a second 90-day period for ACI attestation, and a third 90-day period for CPIA attestation.
Public and Portable
The federal Final Rule that operationalized MIPS provides that scores for both individuals and groups will be published for each program year. Specifically, scores will be posted to a publicly accessible website. Therefore, when formulating a reporting strategy, providers must consider the impact of MIPS performance on the public’s perception of quality.
MIPS scores are also “portable,” which means a provider’s MIPS score will always be associated with that provider’s NPI, whether that provider changes reporting method or to a new tax identification number.
How is the Composite Performance Score Calculated?
The following is an example of how the Composite Performance Score will be calculated from the individual performance category scores in 2017.
|Category||Category points earned||Category points available||Category performance||2017 category weight||Contribution to CPS|
|= (points earned) / (points available)||= 100 x (category performance) x (2017 weight)|
|Cost||Not applicable in 2017||0%||0|
|Composite Performance Score||73.25|
Is There an Incentive to Report MIPS?
The Composite Performance Score ultimately determines the magnitude of any financial incentive or penalty received by a MIPS eligible provider. The incentive or penalty is implemented as an adjustment to the provider’s Medicare Part B reimbursements two years into the future, i.e. performance in 2017 will affect payments in 2019. Note that:
- Payment adjustments are made the claim line item level.
- Payments for Part B drugs are not impacted by payment adjustments because Part B drug reimbursement is based on average sales price.
To determine the incentive or penalty, a provider’s CPS is compared to a performance threshold established by CMS. Scores above the threshold earn an incentive, while scores below the threshold receive a penalty. The further above or below the performance threshold, the greater the magnitude of the adjustment. Scores equal to the threshold receive no adjustment.
The maximum incentive (for CPS = 100) and maximum penalty (for CPS = 0) change over time according to the following schedule:
This component of MIPS is budget-neutral, meaning those providers that are penalized pay for those that receive incentives. For this reason, the maximum incentive in any given year may be increased (up to 3X) or decreased to ensure budget-neutrality.
In 2017, the performance threshold is three (3) CPS points. Thereafter, it will be set at the mean or median of all CPS scores from a prior period.
Adjustment factor as a function of Composite Performance Score for the 2017 MIPS program year. The blue line is the adjustment factor with no scaling for budget-neutrality. The dotted orange line is the maximum possible adjustment factor if permitted by budget-neutrality.
Additional Performance Threshold
For program years 2017-2022 (payment years 2019-2024), CMS has set aside an additional $500 million per payment year to incentivize top performing providers under MIPS. This component of MIPS is not budget-neutral.
To be eligible for this additional incentive, a provider must have a CPS greater than or equal to an additional performance threshold. Scores at the additional performance threshold earn an additional 0.5% incentive. The maximum additional incentive (for CPS = 100) is an additional 10%, although this may be decreased to ensure the sum of all additional incentive payments does not exceed $500 million.
In 2017, the additional performance threshold is seventy (70) CPS points. Thereafter, it will be set at the 25th percentile of the range of possible CPS scores above the performance threshold for the corresponding performance year.
Additional adjustment factor as a function of Composite Performance Score for the 2017 MIPS program year. This graph assumes no scaling is needed to ensure that additional incentive payments do not exceed $500 million.
The total fee schedule adjustment is the sum of the two adjustment factors described above.
Combined adjustment factor as a function of Composite Performance Score for the 2017 MIPS program year. This graph assumes no scaling of either the adjustment factor or the additional adjustment factor.