In an effort to further their support of clinicians, the Center for Medicare and Medicaid Services (CMS) has decided to release preliminary performance feedback on the Quality Payment Program (QPP) website as soon as the data is received. Additionally, CMS is introducing Final Score Preview in June, allowing clinicians to review their 2021 final score for 2023 Merit-Based Incentive Payment System (MIPS) payment adjustments.
Why has CMS made this change?
According to Susan Lofton, Digital Health and Clinical Transformation Specialist at Keet as well as the Executive Director of Keet’s Qualified Clinical Data Registry (QDCR) , CMS releasing performance information in August—well after clinicians had submitted their data for the previous year and moved on to other concerns—was too late for many who were preoccupied with patients and unable to take the time to check if there were any errors in their final score, or simply unable to recall that far back. Many clinicians failed to realize the importance of verifying the performance scores—an issue that was highlighted when CMS made an error with the 2020 MIPS performance year scores they put out to all MIPS-participating clinicians that they later had to retract.
With this change, Lofton notes that the relevant information will be fresher in the minds of clinicians, with more opportunity for clinicians to spot errors and to reach out to CMS before getting paid—provided that they take the time to log into their HCQIS Access Roles and Profile (HARP) account ahead of time.
What should I do if there’s an error in your final score?
PTs, OTs and other clinicians shouldn’t assume everything in the MIPS preliminary score is correct. Lofton notes that a common error she’s encountered is PTs being misidentified as MDs, and thus being docked for missing two of the four MIPS categories.
If you’re a clinicians that’s noted an error in your data or score, Lofton recommends one of two methods for reaching out to CMS: you can reach out directly through QPP (the phone number is 1-866-288-8292 and the email is QPP@cms.hhs.gov) or you can work with your digital health vendor to get their support in addressing any discrepancies. Working with your vendor can be beneficial to those without experience in dealing with this particular issue, as vendors like Keet offer templated formats for making the case to CMS that your payments aren’t correct.
You can find the 2021 Preliminary Feedback Fact Sheet in the QPP Resource Library, along with other resources on what you need to know about MIPS.
