The Centers for Medicare & Medicaid Services (CMS) has released preliminary data for the 2019 Medicare Quality Payment Program (QPP), which shows more than 95% of participating clinicians earned an incentive payment that they’ll see next year.
However, Texas Medical Association experts are skeptical of the preliminary data. They say the numbers result in what appear to be overwhelmingly positive statistics without fully addressing adjustments to participants’ scores , such as waivers participants received under the Extreme and Uncontrollable Circumstances Policy.
The 2019 performance year was the third for QPP, which allows clinicians to participate through either the Merit-Based Incentive Payment System (MIPS) or through an alternative payment model. Physicians earn incentives or incur penalties in the program two years out, meaning the 2019 results will be reflected in 2021 payments.
For the 2019 performance year, clinicians needed to score more than 30 points to receive an incentive payment, with 75 points being the threshold for receiving an additional payment for exceptional performance.
TMA experts are dubious of CMS’ claim that 4.36% of MIPS participants finished 2019 with a final score right at the 30-point threshold, a significant increase from 2018’s 0.45%. CMS also doesn’t mention how many of the participants who met the threshold requested waivers for extreme and uncontrollable circumstances, according to TMA’s initial analysis. In addition, significantly more clinicians were required to participate in QPP in 2019 than in 2018, making the comparison of the two performance years inapt.
CMS Administrator Seema Verma announced in a blog post that the bonus for exceptional performance in 2019 would be 1.79% of a practice’s Medicare billings. CMS acknowledged that other clinicians, though, “may see lower than expected positive payment adjustments,” i.e. incentive payments, because the program is budget-neutral and a higher number of participants facing maximum penalties qualified under the Extreme and Uncontrollable Circumstances Policy.
TMA will continue to analyze the CMS preliminary data, as well as any forthcoming statistics regarding the program, which remains an ongoing concern and point of advocacy for medicine. Texas physicians have raised questions about QPP’s usefulness and fairness as the program has evolved, saying it is getting increasingly complex, administratively burdensome, and disadvantageous for small practices.
In TMA’s 2018 Survey of Texas Physicians, 65% of respondents said they don’t believe QPP improves patient care, and 74% said they wanted CMS to discontinue all incentive payments and penalties in the program “until cost and quality measures are properly risk-adjusted and consider socioeconomic variables or social determinants of health.”
Earlier this year, as it has for several years running, TMA submitted formal comments to CMS detailing QPP’s shortcomings and said the program was “a constantly changing and moving target.” TMA continues to advocate for improvements to make the program fairer and less burdensome.