Searching for the MIPS ROI: Is Perfect the Enemy of Good?

Joy Rios, MBA is a QPP & MIPS Subject Matter Expert, Consultant, Trainer, “HIT Like a Girl” Podcast Co-Host and course developer for the 4MedPlus MACRA-MIPS certification series. To learn more about Joy, visit:

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As someone who’s spent the better part of a decade consulting on quality programs with healthcare organizations of all sizes and specialties, I find it’s rare to meet a doctor or practice administrator who is genuinely happy about all the changes the Centers for Medicare and Medicaid (CMS) has brought to their organizations. However, the frustration level I’ve been hearing from them lately feels different than just a general resistance to change.

For many, despite their best efforts to keep in line with government requirements, align staff, technology, and financial resources to overcome the hurdles of changing workflows, new software systems, etc., they seem to struggle with the cost/benefit analysis and are legitimately questioning whether it’s worth it to put so many resources into a hyper-focus on Merit-based Incentive Payment System (MIPS).

Attempting to appease a loud group of frustrated clinicians at the start of the program, CMS made it arguably too easy to avoid the penalty in both 2017 and 2018, when only four and five percent of Medicare Part B was at risk. However, since the program is budget neutral, this decision also significantly reduced the incentives available to those who participated fully in the program.

Now, as people look at the historical data, a perfect score of 100 earned in 2017 yielded a whopping 1.88 percent increase in their 2019 reimbursement rate. A perfect score in 2018 yielded just 1.68 percent.

Although the predictions for 2019 and 2020 are much more favorable at 4.69 and 5.78 percent respectively, I think clinicians are getting tired of being sold on the value of this program. They feel like they’re spending a whole lot of dollars to get a few cents in return.

The scary part, is that now that the stakes are at their height (i.e. nine percent of Medicare Part B reimbursement is at risk in 2020), and clinicians can expect to reasonably control 85/100 MIPS points because of the cost category, it’s a little crazy to think that the “Exceptional Performance” score in 2020 is also at 85 points this year.

I brought up some of the challenges in last week’s #HITsm chat.

At Chirpy Bird, we typically tell our clients to consider their best and worst case overall MIPS points scenarios, considering the cost category, worth 15 points. Regardless, they should aim to be Exceptional Performers.

However, in the 2020 model, the bar has essentially been raised so that those expect to lock in a minimum of an additional 0.5 percent in incentives in 2022 must have perfect performance in each of the Quality (45 points), Promoting Interoperability (25 points), and Improvement Activities (15 points) categories.

For those who are just beginning their MIPS journeys, such as all the newly eligible clinicians as of 2019, many practices are still refining their internal workflows around data collection and methods of communication between humans and technology. They are challenged with integrating their EHR with other technologies, investing in licenses, training, staff time, etc. The expectation to have have all of these dialed in perfectly right now is just plain unrealistic.

As MIPS consultants, it’s getting more difficult to find successful strategies that can guarantee a perfect score.

There’s no getting around it: CMS is asking for a lot. The burden, especially for the administrators of smaller practices, are such that despite putting their best efforts toward being good stewards of this program and are still struggling to see the return on their investment.

I don’t have a fix. I’ve tried to remain neutral about my opinion about whether MIPS is good or bad, but instead focus on educating clinicians on the actual rules, so that they can navigate the program as effectively as possible.

I empathize with the positions clinicians are in this year. Although we continue to tout the importance of building a long-term narrative around value-based care in healthcare organizations, I fear that if perfection is the new standard, people are going to lose steam.

Author:  Joy Rios

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Joy Rios, MBA is a QPP & MIPS Subject Matter Expert, Consultant, Trainer, “HIT Like a Girl” Podcast Co-Host and course developer for the 4MedPlus MACRA-MIPS certification series. To learn more about Joy, visit:

Follow Joy on twitter! @