Payment & Delivery Models

MIPS penalties could reach 9%: What doctors should do now

Kevin B. O'Reilly , Senior News Editor

AMA News Wire

MIPS penalties could reach 9%: What doctors should do now

Sep 20, 2023

For the first time since the Medicare Merit-based Incentive Payment System (MIPS) started, there are alarming reports that physicians are facing penalties under the program.

The Centers for Medicare & Medicaid Services (CMS) made available 2022 MIPS performance feedback in August. Performance in 2022 determines whether physicians will get a positive, neutral or negative payment adjustment on the Medicare services they deliver in 2024. These penalties can cut Medicare payment by as much as 9%.

The AMA is advocating for you

The AMA has achieved recent wins in 5 critical areas for physicians.

Doctors should review that performance feedback on the Quality Payment Program website using their HCQIS Access Role and Profile (HARP) credentials. The AMA is strongly encouraging physicians to view this information as soon as possible.

For help registering for a HARP account, access the QPP Access User Guide (ZIP). 

The CMS Payment Adjustment User Guide walks through the process of accessing and downloading performance feedback. Download it now (PDF).

If there are any errors, physicians should consider submitting an appeal, also called a targeted review. The deadline to submit a targeted review is Oct. 9, 2023. For more information about how to request a targeted review, please refer to the 2022 Targeted Review User Guide (PDF).

Related Coverage

Another year of Medicare physician pay cuts is unconscionable

Examples of previous targeted review circumstances include the following:

  • Data were submitted under the wrong taxpayer identification number or national provider identifier.
  • Eligibility or special status issues. For example, a physician has Qualifying APM Participant status and should not get a payment adjustment.
  • Performance categories were not automatically reweighted even though a physician qualified for reweighting due to extreme and uncontrollable circumstances.

CMS generally requires documentation to support a targeted review request, which varies by circumstance. A CMS representative will contact physicians and practices about providing any specific documentation required. If the targeted review request is approved and results in a scoring change, CMS will update the final score and associated payment adjustment, if applicable. These targeted review decisions are final. 

Members save on loans & financial services

AMA members get low-rate student loan refinancing from Laurel Road, and a full suite of coverage through AMA Insurance.

Share your data to reshape pay landscape

Another important reason for physicians to review their MIPS performance feedback is to share the information with the AMA to boost its fight against Medicare physician payment cuts in 2024.

Physicians who feel comfortable doing so can share deidentified score and corresponding payment adjustment information. That will inform the AMA’s understanding of the impact of MIPS on physician payment in 2024 and help guide conversations with the Biden administration and Congress about ensuring physician payment supports high-quality care to Medicare patients. Share your information by emailing the AMA Advocacy staff

Leading the charge to reform Medicare pay is the first pillar of the AMA Recovery Plan for America’s Physicians.

The AMA has challenged Congress to work on systemic reforms and make Medicare work better for you and your patients. Our work will continue, fighting tirelessly against future cuts—and against all barriers to patient care.

Explore the AMA's Medicare Basics series, which provides an in-depth look at important aspects of the Medicare physician payment system—including MIPS. Through straightforward explanations, policymakers and physician advocates can learn about key elements of the payment system and why they are in need of reform.