You know, keeping up with Medicare’s Merit-Based Incentive Payment System (MIPS) can feel like a full-time job. It’s easy to make mistakes, and some of them can really hit your bottom line. We’re talking about losing thousands of dollars in reimbursement, which nobody wants. Let’s look at some common MIPS errors that could be costing you money.
Key Takeaways
- Failing to submit any MIPS data at all when you are eligible for the program results in the maximum penalty of a 9% reduction in Medicare Part B payments.
- Submitting incomplete data across MIPS categories, even with good performance in others, can significantly lower your overall score and lead to penalties.
- Performing poorly in crucial MIPS categories like Quality or Cost, even if you submit data, can drop your Composite Performance Score (CPS) below the threshold needed to avoid penalties.
- Technical issues such as incorrect file formats, outdated EHR systems, or wrong provider identifiers can cause data rejection or incomplete reporting, leading to incomplete data completeness and potential penalties and/or auditing.
1. No Submission
It might seem counterintuitive, but one of the most straightforward ways to miss out on MIPS reimbursement is simply by not submitting your data at all if you are eligible. You might think, “Why bother submitting if CMS can figure it out?” Well, while CMS does have ways to calculate a score using Medicare claims data, relying on this automatic process can leave significant money on the table. Failing to actively participate in the Quality Payment Program (QPP) means you’re essentially forfeiting the opportunity to demonstrate your practice’s high performance and earn positive payment adjustments.
A. Automatic Scoring Limitations: CMS’s automatic scoring method may not accurately reflect quality initiatives or patient care nuances, potentially leading to less favorable payment adjustments.
B. Missing the Opportunity for Bonus Points: Non-submission of MIPS data can result in missing out on potential bonuses, impacting overall payment adjustment.
C. Lack of Control Over Your Data: Lack of control over data submission can result in inaccurate representation of performance. Active participation in the MIPS program is crucial for maximizing reimbursement potential and accurately reflecting quality of care.
2. Partial Reporting
When you submit your MIPS data, it’s not enough to just send something in. You need to make sure you’re reporting on all the required categories, meeting CMS data completeness requirements and the case minimum for various measures. If you skip a section or only provide partial information, you’re leaving money on the table. CMS requires you to report across Quality, Promoting Interoperability, Improvement Activities, and Cost. Failing to report on even one of these can significantly impact your final score and, consequently, your payment adjustment. Think of it like this: you wouldn’t submit only half of your tax return, would you? The same principle applies here.
The Impact of Incomplete Submissions
Submitting partial data can lead to a few undesirable outcomes:
- Zero Scores for Missing Categories: If you don’t report on a category, you’ll likely receive a score of zero for it. This can drastically lower your overall MIPS score.
- Inability to Earn Bonuses: Many performance bonuses are tied to comprehensive reporting. Missing data means missing out on these opportunities to boost your score.
- Potential Penalties: In some cases, incomplete reporting can be treated as non-compliance, potentially leading to penalties and or audits instead of incentives.
What Constitutes Partial Reporting?
Partial reporting can happen in several ways:
- Skipping Entire Categories: Not submitting data for one or more of the four MIPS performance categories.
- Incomplete Measure Sets: Reporting only a few measures within the Quality category instead of the required number.
- Missing Required Data Points: Within a reported measure or activity, failing to include all necessary data elements.
- Not meeting CMS data completeness requirements and/or case minimums for various measures.
It’s vital to understand that MIPS is designed to measure your performance holistically. Providing only a piece of the puzzle means CMS cannot accurately assess your overall performance, and you will not receive the full reimbursement you could have earned.
3. Low Performance
It’s not just about submitting complete data; it’s also about the quality of that data and how it stacks up against the national CMS benchmarks. Your performance in the MIPS categories directly impacts your final score. If your reported performance falls short, you could be looking at a significant penalty. Think about it: if you’re not hitting the benchmarks for quality measures or if your cost category data isn’t strong, your Composite Performance Score (CPS) will suffer. This score is what determines whether you get a bonus, no penalty, or a hefty deduction.
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Poor Scores in Quality Measures: Low scores result from failing to meet clinical outcome targets, similar to poor test grades affecting overall performance.
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Weakness in Cost Category: High costs without justification can lower your score, even if care quality is high, as CMS compares provider efficiency.
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Miscalculations in Performance Scoring: Errors in score calculations, such as misapplied benchmarks or incorrect patient attribution, can distort performance results.
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Discrepancies in Quality or Cost Score Calculations: Miscalculations in quality or cost scores, due to incorrect benchmarks or patient attribution, can significantly affect reimbursement.
- Missing Promoting Interoperability Required Measures: There are certain measures within this category that are required in order to receive credit. If you miss one of the required PI measures, the whole category results in a “0” performance.
4. Missed by a Fraction
Navigating the Merit-based Incentive Payment System (MIPS) requires understanding its nuanced, budget-neutral payment structure. Unlike a simple pass/fail system, MIPS operates on a linear sliding scale where every point matters. Your final score is compared to the performance threshold—currently 75 points—to determine your adjustment.
The closer your score is to 75, the closer you are to a neutral payment adjustment. However, the further your score falls below that threshold, the larger your negative payment adjustment becomes. Because the system is budget-neutral, this means that even a score of 74.99 will result in a negative adjustment, while a score just above 75 will earn a positive one. This unforgiving reality makes every fraction of a point financially significant.
Miscalculations in Quality or Cost Scores
Incorrect data completeness can lower benchmarking quality measure scores. Inaccurate patient or service attribution to your TIN by CMS can skew cost performance, especially in multiple practices or APMs.
Incorrect NPI-TIN Attribution
Your NPI and TIN are crucial for MIPS scoring. Mistakes, like being linked to the wrong TIN or including data from a previous practice, can distort performance results and affect your composite score, since MIPS payment adjustments typically follow the NPI/TN combination.
Errors in Performance Category Reweighting
Reweighting can occur due to hardship exemptions or special status. Incorrect application by CMS can unfairly lower your score or introduce zero-weighted categories, negatively impacting your MIPS score. Incorrect or lack of reweighting can occur if you don’t complete (and receive acceptance) of the correct EUC and/or PI hardship.
Special Status or Eligibility Designation Mistakes
Providers with special status, such as small practices, gain scoring advantages. Incorrect identification of this status can lead to missed benefits, resulting in a lower score, potentially affecting bonuses or penalties. Make sure you know and understand your eligibility and current status of your TIN by logging into QPP as a security official to see all details about your TIN.
5. Technical Errors
A. Data Submission Errors by Third-Party Vendors
Sometimes, you might rely on your Electronic Health Record (EHR) system, a Qualified Registry, or a QCDR to submit your MIPS data. While this can simplify things, errors can still creep in. These might include incomplete data being sent, files being formatted incorrectly, or even submitting data for the wrong performance year. These technical glitches can lead to missing categories, incomplete reporting, or even a non-submission being recorded, all of which could result in a lower payment adjustment. Be sure you are reviewing your data early and often with your vendor to ensure accuracy. Don’t just send the data over and hope for the best. Actively monitor your data and engage with your vendor on a consistent basis to review and remediate any data issues detected.
B. Incorrect NPI-TIN Attribution
MIPS scoring is tied to your NPI and TIN combination. CMS can skew results if performance data is incorrectly attributed to the wrong TIN, especially if you switched practices or if TINs aren’t properly linked. Be sure to check eligibility for all your potential participants.
C. Incorrect Special Status or Eligibility Designation
CMS offers automatic scoring advantages or exemptions for providers who qualify for special status. For instance, if you’re part of a small practice, you might have different reporting requirements or receive different scoring considerations. An incorrect designation here could mean you miss out on these benefits, impacting your final score. Be sure you understand your status and that it aligns with what CMS displays when you log into QPP.
D. Data Errors Leading to Score Reduction
Even if your data is submitted correctly, errors in how it’s processed can hurt your score. This could involve introducing a zero-weighted category, which pulls your overall score down, or misallocating weight to a category that wasn’t reported as well as it could have been. It’s important to review your submission carefully to avoid these pitfalls.
E. Discrepancies in Quality or Cost Score Calculations
Quality and cost scores can be miscalculated due to incorrect measure benchmarks or decile assignments, especially for providers in multiple group practices or Alternative Payment Models. It’s crucial to verify accurate data and identify technical errors, often through internal audits prior to submission and targeted reviews after submission if errors are detected late in the process.
Dealing with technical glitches can be a real headache. If you’re running into issues, don’t worry! We’ve got your back. Check out our website for easy-to-follow guides and support to get things running smoothly again.
Don’t Let MIPS Mistakes Cost You
Mistakes in MIPS can lead to significant financial losses, especially when dealing with patients. Mistakes such as missing deadlines, sending incorrect files, or not understanding rules can significantly impact a practice’s income. It’s crucial to take the time to correct these errors or seek help to avoid losing thousands of dollars due to reporting errors. It’s essential to avoid these penalties and ensure your practice’s financial stability.
