• MIPS 2017—Bonuses and Penalties: How CMS Determines Whether You Get a Bonus or a Penalty

    By Rebecca Hancock, Flora Lum, MD, Chris McDonagh, Cherie McNett, Jessica Peterson, MD, MPH, and Sue Vicchrilli, COT, OCS

    This Practice Perfect content is part of EyeNet’s Guide to MIPS 2017.


    How CMS Determines Whether You Get a Bonus or a Penalty 

    Your MIPS final score for 2017 will impact your 2019 Medicare reimbursement. The Centers for Medicare & Medicaid Services (CMS) will use your 2017 final score to determine both:

    • your 2019 payment adjustment factor, which can be positive, neutral, or negative, depending on whether your final score exceeds, meets, or falls below the 3-point performance threshold; and
    • your 2019 additional payment adjustment factor, which rewards those who meet or exceed the 70-point additional performance threshold.

    First, CMS calculates your 2017 final score, which for most physicians can range from 0 to 100 points. It is a composite score that will be based on your scores in 3 performance categories, which will usually be weighted as follows:

    • Your quality score contributes up to 60 points to your final score. The quality performance category replaces the Physician Quality Reporting System (PQRS).
    • Your advancing care information (ACI) score contributes up to 25 points. The ACI performance category replaces the electronic health record (EHR) meaningful use program.
    • Your improvement activities score contributes up to 15 points. This is an entirely new performance category.

    Note: In unusual cases, the weighting of these performance categories may vary (see “When You Don’t Have an EHR System” below).

    CMS compares your 2017 final score against the 3-point performance threshold to determine your 2019 payment adjustment factor. If your final score is:

    • 0 points, your payment adjustment factor is –4%; 
    • 3 points, your payment adjustment factor is neutral (no penalty, no bonus); or
    • more than 3 points, you will get a small positive payment adjustment factor, based on a linear sliding scale (see purple line in “Payment Bonus” chart).

    CMS also compares your 2017 final score against the 70-point additional performance threshold to see if you get a 2019 additional payment adjustment factor. If your final score is:

    • 70 points or more, you get an additional payment adjustment factor, based on a linear sliding scale. (The orange sliding scale in the “Payment Bonus” chart represents the sum of the payment adjustment factor and the additional payment adjustment factor.)

    CMS plans to publish your MIPS scores online. Your scores for the various performance categories will be posted on the Physician Compare website, which is open to the public.

    When You Don’t Have an EHR System

    In most cases, if you don’t have an EHR system, your ACI score will be 0 points. This means that your maximum possible final score would be 75 points (up to 60 points for quality and up to 15 points for improvement activities). In 2017, you can still exceed the 3-point threshold and get a positive payment adjustment factor, but it will be very hard to reach the 70-point additional performance threshold and get the additional payment adjustment factor. In future years, as CMS ramps up the rewards and risks, this 25-point disadvantage will become increasingly significant.

    In limited circumstances, you might not be scored on ACI. You may, for example, have been prevented from reporting the ACI measures because of extreme and uncontrollable circumstances, such as a natural disaster that destroyed your EHR system. In that case, it would be unfair for CMS to give you an ACI score of 0. Instead, CMS doesn’t assign you an ACI score, and it bases your final score on the other 2 performance categories, with your quality score contributing up to 85 points and your improvement activities score up to 15 points. (For other circumstances in which you may be exempt from ACI, see “Guide to MIPS 2017, Part 3: How to Report Advancing Care Information” in the March 2017 EyeNet.)

    ___________________________

    This content is excerpted from Part 5: Calculating Bonuses and Penalties (Practice Perfect, May 2017 EyeNet), which is part of EyeNet’s Guide to MIPS 2017. Part 5 includes How CMS Determines Whether You Get a Bonus or Penalty, The Payment Adjustment Factor, The Additional Payment Adjustment Factor, How the Bonuses and Penalties Will Be Applied, and Payment Bonus Chart.

    Note: This content was based on the information available at time of press; CMS is still publishing its regulatory guidance for MIPS.

    Use These Resources

    Academy MIPS resources include dedicated MIPS and Medicare pages.

    AAOE members can share MIPS tips via the e-Talk and e-Retina listservs.

    Sign up for the IRIS Registry, which will be the tool of choice for MIPS reporting.