2017 was the first year for participation in the Merit-based Incentive Payment System (MIPS), a Quality Payment Program (QPP) implemented by CMS, to award or penalize participating clinicians with regard to future Medicare reimbursements based upon reporting under four categories:
In July, CMS released 2017 Performance Feedback Reports detailing clinicians’ MIPS final scores, performance category details, and 2019 MIPS Medicare payment adjustments. According to CMS, approximately 621,700 providers received negative adjustments. At the same time as release of reports, CMS conducted a “targeted review” and discovered major calculation errors in the following areas:
On September 25th, CMS announced that clinicians have 20 days to request a targeted review of their MIPS report. Lack of transparency by CMS has buoyed critic positions that MIPS is too complicated. CMS, however, states that it has “reviewed the concerns, identified a few errors in the scoring logic, and implemented solutions. The targeted review process worked exactly as intended, as the incoming requests quickly alerted us to these issues and allowed us to take immediate action.”
Clinicians are encouraged to review Performance Feedback Reports and request a targeted review by Oct. 15, 2018, at 8:00 pm EDT.
What is a targeted review, and how do I submit a request?
Clinicians must request a Targeted Review through the formal online process established by CMS and available at https://cmsqualitysupport.service-now.com/navpage.do. The Performance Feedback Report may be found at the QPP Portal, https://qpp.cms.gov/login.
No targeted review is available for:
CMS will generally require additional supporting documents that the clinician must provide within 30 days. All targeted review decisions are final and without further review.
Clinicians should be prepared to submit supporting documents:
CMS is in the process of reviewing over 15,000 comments on a proposed rule that was issued in July to outline changes for year three of the MIPS Quality Payment Program and update the Medicare physician fee schedule. The final rule will be issued later this fall.
Beth Pitman is Of Counsel with Waller Law where she specializes in health law.
Thank you to Tayler Chambless, Belmont University College of Law, for her assistance in preparing this article.
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