2024 MIPS Payment Adjustments

In August 2023, CMS released 2022 MIPS final scores and associated 2024 MIPS payment adjustment information to MIPS eligible clinicians. The 2024 MIPS payment adjustment, which is based on 2022 final performance scores, will affect payments made for services in calendar year 2024, also referred to as the 2024 MIPS payment year.  MIPS eligible clinicians may begin to see MIPS-related adjustments to their Medicare Part B payments starting in January 2024. Payment adjustments are made on a claim-by-claim basis and may be positive (i.e., an increase to the Medicare paid amount), negative (i.e., a decrease to the paid amount), or neutral (i.e., no adjustment).

Keep in mind that MIPS payment adjustments are tied to unique Taxpayer Identification Number/National Provider Identifier (TIN/NPI) combinations. Thus, a single clinician, identified by NPI, that billed Medicare under multiple TINs during 2022, can receive a separate 2022 MIPS final score—and therefore a different 2022 MIPS payment adjustment— for each of their unique TIN/NPI combinations.

Also keep in mind that MIPS affects Medicare Part B payments, regardless of a physician's employment status, which means hospital-based and hospital-employed physicians are generally expected to comply with the program's requirements. The reimbursement your hospital receives for your services will be impacted by your performance under the program, which may directly or indirectly impact your compensation. HRS encourages employed members to ensure that reporting requirements are being met, even if that reporting is administered by your facility.

Unfortunately, the number of clinicians subject to a MIPS penalty in 2024 is expected to be higher than in the past due to various factors that affected performance in 2022, including:

• CMS's decision to resume calculation of scores under the Cost category following a pause during the COVID-19 public health emergency (PHE);
• Adoption of a higher MIPS performance threshold, which is the minimum number of points a clinician must earn under the program to avoid a penalty; and
• The expiration of automatic COVID-19 exceptions that were offered during the PHE.

As a result of these shifting policies, some physicians will face MIPS penalties in 2024 for the first time since the program started. At the same time, since MIPS is a budget neutral program, those who performed well in 2022 might receive positive payment adjustments that are higher than in the past.

HRS continues to support efforts by the American Medical Association and other stakeholders to urge CMS to mitigate 2024 MIPS payment cuts, which will be compounded by the almost 3.4% reduction to the conversion factor in 2024. However, as we enter the new year and CMS begins to apply these MIPS payment adjustments to 2024 claims, the prospects of a MIPS-related resolution are waning.

Additional information about MIPS payment adjustments, including how to access 2022 performance feedback and 2024 payment adjustment amounts, can be found in this CMS 2024 MIPS Payment Year Payment Adjustment User Guide. Should you have any questions about your 2022 performance and/or 2024 payment adjustment, please contact the Quality Payment Program Service Center by email at [email protected] or phone at 1-866-288-8292.