In a recent blogpost, CMS released the final results for the 2018 performance year of the Quality Payment Program (QPP).  While individuals and groups have had access to their own scores since this past Summer, this new analysis provides a look into the performance of the entire population of QPP participants during the second year of the program.

MIPS Track

2018 participation rates for the Merit Based Incentive Program (MIPs) track of the QPP exceeded rates from 2017, with a higher percentage (98%) receiving a positive payment adjustment onto their 2020 Medicare part B payments.  This is a 5% increase over the 2017 performance year which required participants to only earn 3 points out of 100 in order to receive a positive adjustment.  Participants were required to earn at least 15 points in 2018 in order to start receiving an incentive bonus.  Despite the bar being raised, more of participants avoided a penalty than the first year of the program which shows an increase in expertise of how to perform against program metrics.

Of those earning incentive payments, 84% earned above the 70 points required to be considered an “exceptional performer”.  CMS sets aside extra funds to be distributed between those that exceed the ‘exceptional performer’ threshold for the first 6 years of the MIPs program, which results in an increased payment adjustment.  In 2017, 71% of those earning incentive payments also qualified to be considered ‘exceptional performers’.

APM Track

Participation on the alternative track of the QPP program (Alternative Payment Model – APM) was also on the rise for 2018, with CMS stating that 183,306 participants earned the Qualifying APM (QP) Participant status which exempts clinicians from reporting traditional MIPs data.  Those that earn the QP status by billing a certain percentage of their Medicare claims through an Advanced Alternative Payment model are eligible for a 5% bonus paid in future years.  2018 Advanced APM participants increased by around 45% over 2017 numbers.  CMS believes this reflects positively on their initiative to promote high-quality, value-based care by offering alternatives to the fee-for-service reimbursement model.


Although numbers are up across the board for the QPP program, positive payment adjustments remain modest under MIPs.  Since MIPs is a budget-neutral program, the penalties collected from those that failed to meet 15 pts in 2018 are used to pay the participants that exceeded the penalty threshold.  This leaves only 2% of participants receiving penalties in 2020, with a maximum negative adjustment of -5%.  The maximum positive adjustment came in at +1.68%, which is a slight decrease over the +1.88% maximum adjustment in 2017.

CMS is encouraged with the results for year 2 and continues to mature the program. 2018 data shows that, overall, participants performed well which provides a smaller opportunity for improvement in year 3.  And, increases in performance thresholds will result in a smaller distribution of positive payment adjustments in future years of the program, meaning top performers will continue to benefit the most while mid-low performers will have more to lose.

As a reminder the submission window for the 2019 performance year is now open and participants are required to earn at least 30 points to avoid a penalty.

To read the full blogpost from CMS, click here:

As always, ADVOCATE will continue to keep you up to date on regulatory information as it becomes available.


Kayley Jaquet

Manager of Regulatory Affairs