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Answers to your 2019 MIPS payment adjustment questions

Payment adjustments for the first year of the merit-based incentive payment system (MIPS) are scheduled to arrive soon, so now may be the time to brush up on any unanswered questions you have about your payment-affecting scores from the 2017 reporting year.
 
One thing to watch out for: the best MIPS performers may be disappointed with their financial bonuses in 2019, CMS notes in a new fact sheet. That's because to maintain budget neutrality CMS can only allot so much money to high performers. If a lot of practices did well in 2017, the bonus money in 2019 may not reach the top-level 4% that CMS has broadcasted.
 
It all comes down to the "scaling factor," or a weight of providers' collective final scores. Here's how CMS describes it in the fact sheet:
 
"If the scaling factor that is applied to positive MIPS payment adjustment factors is less than 1.0, a clinician who received a final score of 100 points will still receive a positive payment adjustment, but the amount of the positive payment adjustment that clinicians will receive will be less than the applicable percent (4 percent) for 2019. Similarly, if the scaling factor is above 1.0, then the amount of the positive payment adjustment for a clinician who received a final score of 100 points will be more than 4 percent for 2019."
 
Ultimately, it comes down to bulk. The more providers with a performance score over the threshold, which in 2017 was three points, the smaller the scaling factor. The same goes for additional bonus money for providers who scored over 70 points.
 
You'll find additional information, as well as multiple Q&As, in the fact sheet. Here's an example Q&A:
 
"Question: Dr. Alice Jones did not exceed the low-volume threshold for 2017 as an individual. She assigned her billing rights to Atlantic Practice Group’s TIN in 2017. Atlantic Practice Group (identified by a TIN) exceeded the low-volume threshold in 2017 and chose to report MIPS data for all individual clinicians billing under its TIN and to have its performance scored & assessed as a group. Atlantic Practice Group received a 2017 MIPS final score of 75 points and will receive a positive payment adjustment. Will Atlantic Practice Group’s score and payment adjustment be applied to Dr. Jones in 2019?
 
"Answer: Yes, the group’s final score and 2019 payment adjustment will be applied to Dr. Jones. The low-volume threshold exclusion is determined at the individual (TIN/NPI) level for individual reporting, at the group (TIN) level for group reporting."
 
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