MIPS Revenge!

February 1, 2024
Medicare Advantage Plans

2023 marked the 5th consecutive year of COVID-related MIPS exceptions that were either automatically granted or available through application. This has resulted in a situation where many providers have not engaged with MIPS content for five years. During this five-year period during which providers may have avoided participation, the program has continued to evolve with penalties increasing and the participation threshold needed to avoid a penalty also increasing.

No More Exceptions

CMS ended the Covid-19 public health emergency declaration on May 11, 2023.  Additionally, CMS has made no mention of any COVID-related MIPS exceptions for 2024. Therefore, there is reason to believe the same exceptions that have allowed many providers to not participate over the last five years will not be available for the 2024 performance period.

What To Do

The first step for any provider is to determine whether they are eligible to participate or not.  Providers may visit the CMS Quality Payment Program Participation Status Page, enter their NPI and click “Check All Years.” This will indicate whether a provider is eligible to participate. If a provider is not eligible, they may choose to do nothing for MIPS, will not be assigned a MIPS score, and will not experience any payment adjustment related to MIPS.

Fee Schedule Adjustment

If a provider is eligible to participate, they may achieve a MIPS score of anywhere between 0 and 100 based on their level of participation. Their 2026 Medicare Part B Physician Fee Schedule will be adjusted based on their 2024 MIPS score, with an adjustment range of anywhere between -9% and +9%.  For the 2024 performance period, a MIPS score of 75 is needed to avoid a penalty.

Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC, CPMA

Dr. Lehrman is a Board Certified Podiatrist, Certified Professional Coder, and Certified Professional Medical Auditor. He is in private practice in Colorado and operates Lehrman Consulting, LLC which provides consultation services regarding coding, compliance and documentation.

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