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Comment & Response
September 10, 2020

Incomplete Picture of Otolaryngologist Performance in the Merit-Based Incentive Payment System

Author Affiliations
  • 1Quality and Data Science, American Academy of Ophthalmology, San Francisco, California
JAMA Otolaryngol Head Neck Surg. Published online September 10, 2020. doi:10.1001/jamaoto.2020.2599

To the Editor I appreciate the hard work and excellent analysis of Merit-Based Incentive Payment System (MIPS) performance in the article by Xiao et al, “Otolaryngologist Performance in the Merit-Based Incentive Payment System in 2017.”1 However, I have 1 major concern with the article’s depiction of otolaryngologists’ performance because it leaves the impression with the readership that this is a complete picture of 2017 MIPS performance. Specifically, the Individual Eligible Clinician File with MIPS scores (both individual and group) has only 376 170 rows, compared with more than 1 000 000 clinicians participating in MIPS. The Centers for Medicare and Medicaid Services described the first year of MIPS as the following: “We calculated that 1 057 824 MIPS eligible clinicians will receive a MIPS payment adjustment, either positive, neutral, or negative. Of that population, 1 006 319 MIPS eligible clinicians reported data as either an individual, as a part of a group, or through an Alternative Payment Model (APM) and received a neutral payment adjustment or better.”2

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