Although more clinicians who participated in year two of the Merit-based Incentive Payment System will receive a bonus compared to year one, there are less participants overall, the CMS announced Friday.
The agency said 97.6% of clinicians who participated in MIPS last year will receive a positive payment adjustment on each of their Medicare Part B claims in 2020, which is slightly higher than 2017 when 93.1% of clinicians got a bonus last year. At the same time, the number of participants in the program dropped from 1.06 million to 916,058.
CMS Administrator Seema Verma said the gain in clinicians receiving a bonus is "a strong sign that our incremental approach and flexible options lead to clinician success in MIPS."
But not everyone saw the figures as good news. The overwhelmingly high percent of clinicians receiving a bonus while participation declines shows major flaws in the payment system, said Darryl Drevna, senior director of regulatory affairs at AMGA.
Too many clinicians are currently left out of the program and it's not hard enough to achieve a positive payment adjustment, he said.
The CMS excluded more clinicians from MIPS in 2018. Clinicians only participated last year if they had $90,000 or higher Medicare revenue and saw more than 200 Medicare patients. The original threshold for exemption was $30,000 in Medicare revenue or fewer than 100 Medicare patients. The CMS estimated the change would leave out about 134,000 clinicians.
"They (the CMS) have excluded too many providers and the only ones left are the high performing groups," Drevna said.
The agency rose the exclusion threshold in response to criticism from small practices that they didn't have enough Medicare patients to justify the infrastructure required to succeed in the program.
Under MIPS, payment adjustments are determined by how well clinicians score in three performance categories: quality, clinical practice improvement and interoperability. Costs accounts for 10% of the score. The score goes all the way up to 100 points.
It was slightly harder to achieve a payment adjustment in year two of MIPS. Clinicians who scored 15.01 points or higher in 2018 got a bonus. In 2017, clinicians only had to score higher than three points to get a bonus.
Those who receive higher scores get a higher payment adjustment. However, it's unlikely clinicians will see substantial bonuses next year because the program is budget neutral and therefore relies on the pool of penalties to dole out the bonuses, Drevna said. Just 1.95% of clinicians received a penalty. The CMS can penalize clinicians for up to 5% of their Medicare Part B payments.
Drevna said the CMS should increase the threshold for bonus eligibility because it's too easy.
"How is it even possible to not get 15 points? You have to just show up and you'll get 15 points," he said.
While MIPS participation decreased, alternative payment model participants increased. The number of clinicians part of advanced alternative payment models rose from 99,076 in 2017 to 183,306 in 2018. Clinicians in those models are excluded from MIPS and eligible for a 5% Medicare payment bonus.
Verma said the rise could be the result of more participation in the Medicare Shared Savings Program.
While Drevna said that's good news, it could decrease after this year as participation in the Medicare ACO program is expected to decline given the changes in the program that forces ACOs to take on risk.
