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

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.

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.

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.

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.