Is It Time to Ask for a Raise?
The Centers for Medicare & Medicaid Services (CMS) released July 3 the 2018 Merit-based Incentive Payment System (MIPS) performance feedback and final score, which includes all MIPS eligible clinician’s or clinician group’s final scores for last year and payment adjustment factors for next year.
Depending on how your clinician(s) did, now may be a good time to ask for a raise. Or it may be a good time to request a CMS targeted review.
In the inaugural year (2017) of the Quality Payment Program (QPP), 93 percent of the MIPS eligible clinicians who participated in MIPS earned a positive payment adjustment and 2 percent earned a neutral adjustment. CMS will release final 2018 performance data in March 2020.
When to Request a MIPS Targeted Review
Clinicians have until Sept. 30, 2019, to review their feedback and submit a targeted review request to CMS if they believe an error in calculating their performance was made. This proactive approach will ensure the correct payment adjustment factor is applied to their Medicare Part B claims at the start of 2020.
Other reasons why a clinician may request a targeted review include (but are not limited to):
- Performance categories were not automatically reweighted
- Eligibility and special status issues
- Errors or data quality issues for the measure(s) and activities submitted
- Wrongly excluded from the Alternate Payment Model (APM) participation list
How to Request a MIPS Targeted Review
Eligible clinicians, groups, and certain APM entities can access the Targeted Review Request form on the QPP portal. Third-party intermediaries, such as qualified registries, health information technology vendors, and qualified clinical data registries, can request a targeted review on a clinician or group’s behalf if authorized to do so.
Targeted reviews must be requested at the same level as the data was submitted to CMS. For example, if a clinician who submitted MIPS performance data under a group’s Tax Identification Number (TIN) believes there is an error in the final score, the entire group needs to request a targeted review.
What to Expect in a MIPS Targeted Review
You will receive a confirmation letter stating CMS received your request, at which time you may be asked for documentation to support the request. This documentation must be received by CMS within 30 days of the request.
Typical requests include:
- Supporting extracts from the MIPS eligible clinician’s EHR
- Copies of performance data submitted to submitter
- QPP service center ticket numbers
- Signed contracts or agreements between a clinician and third-party
- APM participation agreements
- Partial QP election forms
Targeted review outcomes are sent via email to the submitter. These reviews cannot be appealed.
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