MIPS 2018 vs 2017: Fewer Eligible Participants but Greater Proportion to Receive Positive Payment Adjustment

July 16, 2019


On July 12, 2019, the Centers for Medicare and Medicaid Services (CMS) published a blog post and infographic to share preliminary participation data for the Quality Payment Program during 2018. Merit-Based Incentive Payment System (MIPS) payment adjustments in CY 2020 will be based on MIPS performance in 2018. Preliminary data indicates that there were fewer eligible participants in MIPS in 2018 versus 2017 (due to changes in program eligibility criteria such as the low volume threshold), but a greater proportion of them participated and a greater proportion exceeded the minimum score needed to receive a positive payment adjustment (performance threshold).

Since MIPS is a budget neutral program with negative adjustments funding positive adjustments, these high participation rates and the high percentage of participants exceeding the performance threshold will likely result in modest payment adjustments well below the maximum 5% positive payment adjustment allowed by statute for CY 2020.

Certain Alternative Payment Models (APMs) include MIPS-eligible clinicians as participants and hold their participants accountable for the cost and quality of care provided to Medicare beneficiaries. These types of APMs are called MIPS APMs, and participants receive special MIPS scoring under the APM scoring standard. Data indicates that MIPS APM participation increased in 2018.




MIPS Eligible Clinician Participation Rate



Total clinicians receiving a MIPS payment adjustment (positive, neutral or negative)


Percent of clinicians performing above the performance threshold*93.12%97.63%

Total MIPS APM clinicians receiving a MIPS score and payment adjustment (positive, neutral or negative)


* The performance threshold in 2017 was 3, and in 2018 it was 15.

Performance feedback reports were made available earlier in July. If a participant believes that there is an error in the report, they may request a targeted review. A targeted review can be requested until September 30, 2019, through the Quality Payment Program website. The Targeted Review Fact Sheet is available here, and the 2018 Targeted Review FAQs is available here.


For more information, visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at +1 202 204 1459 or

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