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  • MIPS 2021—Bonuses and Penalties

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    This content is excerpted from EyeNet’s MIPS 2021; also see the Academy’s MIPS hub page.

    Bonus or penalty? Your 2021 MIPS final score (0-100 points) will impact your 2023 Medicare Part B payments as shown below.

    Table: Bonuses and Penalties

    2021 MIPS Final Score 2023 Payment Adjustment
    0-15 points Maximum penalty of –9%
    15.01-59.99 points Penalty on a sliding scale (see table below)
    60 points Neutral (no penalty, no bonus)
    60.01-84.99 points Initial bonus*
    85-100 points Initial bonus* + exceptional performance bonus†

    * The initial bonus is based on a linear sliding scale—those who score 60.01 points get the lowest bonus; those who score 100 points get the highest.

    † The exceptional performance bonus is based on a linear sliding scale—those who score 85 points get the lowest bonus; those who score 100 points get the highest.

    Table: Payment Penalty

    If your 2021 MIPS final score is less than the 60-point performance threshold, your 2023 Medicare Part B payments will be reduced as shown below.

    Payment Penalty

    Although CMS has set the negative payment adjustment (as shown above), it doesn’t yet know what the positive payment adjustments will be. The bonus for scoring more than 60 points (the initial bonus) will be funded by payment penalties. Consequently, CMS won’t be able to estimate how much money is in the bonus pool—and how many clinicians will be entitled to money from that pool—until it has calculated the MIPS final scores of all MIPS participants, which can’t happen until the performance year is over.

    Similarly, until CMS knows how many MIPS eligible clinicians have scored at least 85 points, and what scores they got, it won’t know how far it has to stretch the $500-millon bonus pool for exceptional performance.

    To date, the initial bonuses and the exceptional performance bonuses have been quite small.

    Why is there a gap year between performance (2021) and payment adjustments (2023)? CMS needs time to process the MIPS data, determine final scores, perform targeted reviews, and calculate adjustment factors for bonuses that ensure budget neutrality.

    CMS has steadily raised the bar. In 2017, the first year of MIPS, you only needed a MIPS final score of 3 points to avoid the payment penalty. This performance threshold increased to 15 points in 2018, 30 points in 2019, 45 points in 2020, and 60 points this year. Next year, CMS has been told to set the performance threshold at a level where about half of MIPS eligible clinicians will be above it and half will fall below it. How high would this performance threshold be? In 2019, CMS had etimated that the 2022 performance threshold could be 74.01 points, but the agency more recently said that it could be even higher than that.

    How the Bonuses and Penalties Will Be Applied

    You can report and be scored as an individual and/or as part of a group. If you are scored as an individual, CMS will use both your Taxpayer Identification Number (TIN) and National Provider Identifier (NPI) to distinguish you as a unique MIPS participant.

    If you and your colleagues report as a group, the group’s TIN will be used as your identifier for scoring purposes.

    You also can report both ways and see which approach scores higher (see “Participate as an Individual or as a Group?”).

    Payment adjustments are always applied at the TIN/NPI level. CMS will apply the payment adjustments at the TIN/NPI level, regardless of whether you were assigned a MIPS final score as an individual or as part of a MIPS group.

    What if you move to another practice after 2021 is over? Your 2021 final score will determine your 2023 payment adjustment, and this is the case even if you move to a new practice after the 2021 performance year is over.

    The payment adjustments will be applied throughout the year. In 2023, CMS will start applying a payment adjustment based on your 2021 MIPS final score. This payment adjustment will be applied throughout 2023 to your Medicare Part B remittances.

    Table: How the Bonuses Are Funded

    2021 MIPS Final Score

    2023 Payment Adjustment

     

    Provenance of Bonus Dollars

    0-15 points

    –9% penalty (negative payment adjustment)

    →

    The negative payment adjustments reduce CMS expenditure. These savings go into a bonus pool that funds the initial bonuses (which are therefore budget neutral).

    15.01-59.99 points

    Payment penalty on a linear sliding scale (negative payment adjustment), as shown in Table: Payment Penalty 

    →

    60 points

    Neutral (no payment adjustment)

    		  

    60.01-84.99 points

    Initial bonus (payment adjustment)

    ←

    These initial bonuses are paid on a linear sliding scale. (Those who score 60.01 points get the lowest bonus. Those who score 100 points get the highest.)

    85-100 points

    Initial bonus (payment adjustment)

    ←

    + exceptional performance bonus (additional payment adjustment)

    ←

    		 Funded by a separate $500-million bonus pool, these exceptional performance bonuses are paid on a linear sliding scale. (Those who score 85 points get the lowest bonus. Those who score 100 points get the highest.)

    Previous: Performance Periods

    Next: Who Does (and Doesn’t) Take Part in MIPS 

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