Congress stepped up to give physicians access to data that can help them improve care for their patients and reduce avoidable costs, yet doctors still do not get the actionable, timely feedback that they need in the Medicare Merit-based Incentive Payment System (MIPS).
The financial stakes for not having the right data are high: For the first time since MIPS began, physicians face penalties that can cut their Medicare payment by as much as 9% in 2024.
In a detailed letter (PDF), the AMA outlined four specific recommendations to correct problems with MIPS data usefulness and frequency and “strongly urged” the Centers for Medicare & Medicaid Services (CMS) to take action on the items to make improvements.
“The need for timely, actionable data has never been greater. Unfortunately, data feedback to physicians has either receded or stalled completely under MIPS. We greatly appreciate your assistance in righting the data ship,” AMA Executive Vice President and CEO James L. Madara, MD, wrote to CMS Administrator Chiquita Brooks-LaSure.
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Dr. Madara emphasized in his letter that “physicians across the country are united” in the need for this timely information and recommended that CMS take these four actions to help get physicians what they need.
Provide timely, actionable MIPS and Medicare data to physicians. Make Medicare claims data and meaningful MIPS attribution, measure and performance data available on a rolling basis or, at a minimum, on a quarterly basis during the actual performance period as the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires.
Resolve discrepancies in MIPS public files. Explain and correct inconsistencies between data files, particularly when it comes to why so many national provider identifiers (NPIs) are missing from the National Downloadable File.
Ensure the Quality Payment Program (QPP) Experience Report accurately reflects MIPS participation. Clarify the number of unique clinicians who participate in MIPS in future QPP Experience Reports and include a breakdown of the different scores unique clinicians receive through multiple groups or alternative payment models (APMs).
Revamp QPP Experience Reports to provide detailed data from both QPP and claims data sources to inform opportunities to improve quality, cut costs and develop MIPS Value Pathways and APMs. Provide detailed information in the QPP Experience Report about performance by specialty, region, site of service and participation option. Reports should display longitudinal trends about whether quality or cost is improving or declining and provide a more complete picture of what makes a particular physician, group practice or APM successful in MIPS.
“CMS needs to remedy inconsistencies and provide a more detailed report as it did in the first year of the QPP,” Dr. Madara wrote.
Learn more with the AMA about MIPS data problems (PDF), a two-page explainer that is part of the AMA’s Medicare Basics series that provides an in-depth look at important aspects of the Medicare physician payment system. Through straightforward explanations, policymakers and physician advocates can learn about key elements of the payment system and why they are in need of reform.
In the 2023 MIPS final rule, CMS estimated that up to one-third of MIPS-eligible physicians and other health professionals would have received a penalty—and it’s likely that the penalties would have disproportionately impacted small practices and practices serving rural or underserved populations.
This would apply to a 2025 penalty, which is based on the 2023 performance period. The exception isn’t automatic and physicians and groups need to actively request the reweighting of one or more MIPS performance categories due to the COVID-19 public health emergency. Applications can be submitted through Jan. 2, 2024.