CMS’s Merit-Based Incentive Payment System (MIPS) is Back Online — Are You Ready?

If you participate in MIPS, you’re on the hook to report — for the first time since the COVID pandemic — or risk financial penalties (of course if you’re doing well, you may get a bonus)


The Merit-Based Incentive Payment System (MIPS), a Medicare program designed to incentivize high-quality care by tying reimbursement to quality and cost-efficient care, will cause more physicians to face financial penalties soon. On August 10, 2023, CMS released MIPS Performance Feedback for performance year 2022, which determines whether physicians receive a payment adjustment in performance year 2024. Physicians, who are dealing with MIPS for the first time since the COVID-19 Public Health Emergency (PHE), now face the potential of a 9% MIPS penalty on top of a 3.36% Medicare Physician Fee Schedule conversion factor reduction. The American Medical Association (AMA) sent a letter to CMS requesting that it extend the time a clinician can contest any discrepancies they believe exist in their payment adjustment calculations. Additionally, the AMA asked CMS to clarify whether physicians can claim “extreme and uncontrollable circumstances” in the wake of the COVID pandemic — which would have their performance categories reweighted to 0% of the final MIPS score — alleviating the burden on providers who may have been unaware that the MIPS program resumed.


On September 28, 2023, the AMA sent a letter to CMS Administrator Chiquita Brooks-LaSure about issues with the MIPS measures.

Key Highlights