Reporting rates of topped-out merit-based incentive payment system (MIPS) quality measures, 2017-2023

Abstract Introduction Merit-based Incentive Payment System (MIPS) quality measures are designated as “topped-out” when reporting clinicians consistently achieve high performance, resulting in potential scoring caps and eventual removal. However, self-selected measure reporting may not provide a representative assessment. Methods Using CMS Quality Payment Program Experience datasets from 2017 to 2023 linked with MIPS Quality Measures Lists and Benchmark data, we examined reporting rates of all MIPS topped-out quality measures among eligible physicians and by specialty at the time of their first “topped-out” designation. Results Between 2017 and 2023, 643,558 physicians reported specialty-relevant measures across 37 specialties and 275 measures, of which 137 (49%) were topped-out. Over half of the topped-out measures had reporting rates below 5%. Only 11 measures were reported by more than half of eligible physicians. The median reporting rate was 7.1% (IQR 1.3%, 28.2%) and varied across specialties, ranging from 0.6% in geriatric medicine to 40.4% in pathology. Conclusion Our findings suggest CMS topped-out designations may not reflect universally high performance for a measure and highlight challenges of MIPS measure self-selection and topped-out designation. Opportunities exist within MIPS design to maintain measures that broadly promote high quality care for all Medicare beneficiaries and continued improvement.