CMS recently announced that targeted reviews of certain 2017 Merit-based Incentive Payment System performance scores resulted in a number of individuals and practices avoiding a penalty and, in some cases, being eligible for a positive payment adjustment.
The calculating errors, first noticed by CMS in the Spring, mostly affected non-anesthesiologists. Those errors included the application of the 2017 Advancing Care Information (ACI) and Extreme and Uncontrollable Circumstances hardship exceptions, the awarding of Improvement Activity credit for successful participation in the Improvement Activities (IA) Burden Reduction Study, and the addition of the All-Cause Readmission (ACR) measure to the MIPS final score.
Because the Medicare Access and CHIP Reauthorization Act (MACRA) MIPS is a budget neutral program, CMS has indicated that “some clinicians will see slight changes in their payment adjustment as a result of the reapplication of budget neutrality.”
According to CMS, revisions were applied to performance feedback reports on September 13, 2018 and are accessible via the Quality Payment Program website.
MIPS ECs and groups who believe an error has been made in their score may request a targeted review. The deadline to submit for a targeted review is now October 15, 2018 and CMS may request practices submit additional documentation to support their appeal. CMS has released several fact sheets and a user guide describing the appeal process.
• Targeted review fact sheet
• Targeted review user guide
• Performance feedback fact sheet
• Payment adjustment fact sheet