Analysis of Payment Adjustments for MIPS Reporting in 2023

Following the conventional sequence of the MIPS program, the participants enter three main phases. For MIPS 2021, CY 2021 was the MIPS reporting phase. And participants got their MIPS final score in August 2022. At last, they enter their payment adjustment phase. MIPS 2021 participants have their payment adjustment time in CY 2023.

Attention here!

No need to confuse MIPS payment adjustment with MIPS performance reporting.

• 2023 is the payment adjustment year from previous MIPS reporting already done in CY 2021.
• However, providers taking part in the MIPS performance reporting in CY 2023 will get adjustments in CY 2025.

Here in this blog, we will overview the details related to the MIPS program taking CY 2023 as a payment adjustment year.

Let’s dig in deeper now!

Payment Adjustment Type in MIPS Reporting

All eligible participants strive hard to fulfill the data completeness requirement for the measures selected. After submitting the whole data for their Medical Part B claim data, they get their MIPS final score. Thus, based on the number of MIPS points they score, providers get their payments. For MIPS 2021, the payment adjustment potential is 7%. So, the participants have clarity. Whatever they are going to get is the fate of their performance entirely.

However, CMS has given three payment adjustment categories to providers. Their MIPS final score decides in which category they fall. The categories and their impacts on payments are given as follows:

Positive Payment Adjustments

A provider can get a maximum of 7% MIPS incentive payments if they can reimburse more than 100%.

Neutral Payment Adjustments

The MIPS neutral payment adjustment is a case when an eligible clinician gets reimbursement to 100% for their medical services.

Negative Payment Adjustments

A provider gets up to 7% MIPS penalty payments if they reimburse less than 100%.

Eligibility for MIPS Payment Adjustments in 2023

CMS gives payment adjustments to MIPS participants only. For MIPS reporting done in PY 2021, the list of eligible and ineligible participants is as follows:

MIPS Adjustments Determination

MIPS reporting framework utilizes a simple method for MIPS payment adjustments. It includes the comparison of the MIPS final score with a pre-set performance threshold. Later, CMS decides to make adjustments.

The CY 2023 payment adjustments have a performance threshold provided early in its reporting period. The clinicians have to score 60 points at least. In other words, those who can secure 60 points or above definitely will get the positive payment adjustment in the 2023 adjustment year.

Traditional MIPS implemented in CY 2023 has faced the termination of MIPS’s exceptional performance bonus. However, this exceptional performance bonus applies to MIPS reporting 2021. At that time, providers who secure 85 points or more will be entitled to this bonus.

However, there are MIPS payment adjustment factors as well. Again, it is the clinician’s MIPS final score that will govern these factors. We have a linear sliding scale used to determine payment adjustment factors.

Relating 2021 Final Score with 2023 Payment Adjustments

MIPS payment adjustment sheet 2023 guides the providers about their adjustment comprehensively.

• If you get 0.00 – 15 points in MIPS final score, you will get a -9% adjustment.
• For scoring 15.01 – 59.99 points, you will be having adjustments somewhere between -9% to zero on a linear sliding scale.
• As we all know, 60 is the MIPS 2021 performance threshold for 2023 payment adjustments. If a participant gets exactly 60.00 points, they will get neutral adjustments. It means, neither they will get a MIPS penalty nor a MIPS incentive.
• MIPS final score from 60.01 to 84.99 points means that you will get a positive payment adjustment of more than 0%. However, your adjustment for MIPS reporting final score is subjected to a scaling factor for keeping the overall budget neutral. Anyhow, the MIPS exceptional performance bonus doesn’t apply to this score.
• If you are among the clinicians who get 85 points or more, this is good news for you. Along with MIPS incentives, you will also get an exceptional performance bonus.

Conclusion

Providers were fully prepared for MIPS reporting in the performance year 2021. They have overcome COVID-19-related risk factors. Therefore, they were in their full form for MIPS 202. CMS has analyzed the data submitted by providers in their MIPS reporting period and given reliable MIPS final scores to them. MIPS payment adjustment in the 2023 calendar year shares their back on the MIPS final score provided a year ago in 2022. The best thing about MIPS 2023 payment adjustments is that providers have been given the maximum opportunity to secure positive adjustments. And for those who haven’t scored well (gone below the performance threshold= 60 points), CMS has tried to save them from a full -7 penalty till their performance points become equal to zero.