High Rates Of Partial Participation In The First Year Of The Merit-Based Incentive Payment System

There has been widespread concern over the design of the Merit-based Incentive Payment System (MIPS) since its authorization with the Medicare Access and CHIP Reauthorization Act of 2015. Using detailed performance data from 2017, the first implementation year of MIPS, we found that although 90 percent of participating clinicians reported performance equal to or better than the low performance threshold of 3 out of 100 (a calculated composite score), almost half of clinicians did not participate in at least one of the three program categories (quality, advancing care information, and improvement activities). The decision to participate in each category explained 86 percent of the total variance in clinicians' overall score, whereas actual performance explained just 14 percent, as a result of the ease of achieving high scores within each category. Still, 74 percent of clinicians who only partially participated in the program received positive payment adjustments. These findings underline concerns that MIPS's design may have been too flexible to effectively incentivize clinicians to make incremental progress across all targeted aspects of the program. In turn, this is likely to lead to resistance when payment penalties become more severe in 2022, as required by the MIPS authorizing legislation.