What’s the news: The final 2023 Merit-based Incentive Payment System (MIPS) performance-year scores are out and the Centers for Medicare & Medicaid Services (CMS) is giving physicians until Oct. 11, 7 p.m. CDT, to ask for an informal review if they believe there are errors in the calculations or the payment adjustment for the 2025 payment year.
The AMA is urging all physicians and practices to log into the CMS Quality Payment Program (QPP) portal to review their final scores.
Oct. 11, 7 p.m. CDT, also is the deadline for MIPS-eligible physicians and groups to apply for a 2023 MIPS Extreme and Uncontrollable Circumstances hardship exception due to the Change Healthcare cyberattack earlier this year. The hardship exception, made available in response to AMA advocacy, allows physicians to request reweighting of up to four MIPS performance categories because of the disruptions due to the cyberattack on your practice.
Note that the hardship exception application will not override data submission. Therefore, if a physician or group previously submitted data for a category, CMS will continue to score that category. Physician practices should consider submitting the application for the cost-performance category, at a minimum, as there are no data-submission requirements for the cost measures, which CMS scores using claims data.
Why it matters: This MIPS score will affect physician practices’ Medicare payment rates, so it is important to ensure that it has been calculated properly.
Just a few examples of what physicians can submit a targeted review for:
- Data was submitted under the wrong taxpayer-identification number or National Provider Identifier.
- A physician has a Qualifying APM Participant status and should not receive a MIPS payment adjustment.
- Performance categories not being automatically reweighted even though you qualify for reweighting because of extreme and uncontrollable circumstances.
To access their MIPS final score and performance feedback request a targeted review, physicians can:
- Sign in using HARP credentials (ACO-MS credentials for Shared Savings Program ACOs); these are the same credentials that allowed submission of 2023 MIPS data.
- Click “Targeted Review” on the left-hand navigation.
CMS generally requires physicians to provide documentation supporting the targeted-review request. A CMS representative will contact physicians about providing any specific documentation required, which varies by circumstance.
If CMS approves the targeted-review request and there is a scoring change, the agency will update the final score or associated payment adjustment as soon as it is technically feasible. Once there is a targeted review decision, it is not eligible for a further review.
The 2023 Targeted Review User Guide (PDF) reviews the process for requesting a targeted review and examples for when a physician would or would not request a targeted review. Meanwhile, the 2025 MIPS Payment Year Payment Adjustment User Guide (PDF) reviews information about the calculation and application of MIPS payment adjustments and answers frequently asked questions.
Physicians who have further questions about whether their circumstances warrant a targeted review can contact the QPP Service center by phone at (866) 288-8292 or by email.
Learn more: The AMA has long been concerned about the undue administrative burden placed on physicians subjected to MIPS reporting requirements, the program’s lack of improvement in patient outcomes and quality of care, and the limited scope of quality measures for specialists.
An AMA MIPS explainer (PDF) notes that evidence of MIPS shortcomings “continues to pile up.” The AMA cites research from JAMA Network™ journals and others showing that, among other things, MIPS scores are inconsistently related to performance, and physicians caring for more patients from historically marginalized racial and ethnic groups were more likely to receive low scores despite providing high-quality care.
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The AMA is leading the charge to reform the Medicare payment system. As part of that effort, the AMA has developed a statutory proposal to replace the MIPS tournament model of payment adjustments with a more sustainable approach that improves the frequency and usefulness of the MIPS data that CMS shares with physicians. Now, CMS calculates metrics on the back end using claims data physicians don’t have a way to monitor their performance, identify opportunities for efficiencies in care delivery and avoid unnecessary costs.
In addition to ensuring timely access to data, organized medicine’s proposed MIPS replacement—called the “Data-Driven Performance Payment System”—would replace steep penalties that are unevenly distributed, reduce unnecessary administrative burdens and increase clinical relevance of the program to physician and their patients.
To help improve the final MIPS feedback process, physicians have an opportunity to give CMS direct feedback on their experiences. Survey participation, which should take no more than 15 minutes to complete, is voluntary and confidential. MIPS-eligible clinicians who complete the survey will receive an Improvement Activity credit.
