Anesthesia MIPS: do not take the Medicare maximum 9% hit
If you are MIPS-eligible and you submit nothing, CMS can apply the statutory maximum negative adjustment: 9% off Medicare Part B professional payments for a full payment year. That year is two years after the performance year. ClearBilling keeps MIPS in the same onshore cycle as your AA, QZ, and QS claims so 'we forgot to report' is not how you fund someone else's bonus.
The 9% is the easy way to lose
MIPS is budget-neutral. The penalty pool is large. The bonus is small. The money is not chasing a 1% upside. It is not walking into a 9% haircut on every Medicare professional claim for a year because nobody submitted.
Performance year 2026 sets the adjustment on 2028 dates of service. The performance threshold is 75 points. A final score at or below 18.75 is the full -9%. Between 18.75 and 75 the cut slides. Confirm current CMS QPP rules for the year you are in. We do not invent thresholds.
Who this actually hits
Not every CRNA or anesthesiologist is MIPS-eligible. Low-volume clinicians can fall out. QPs in Advanced APMs can fall out. Everyone else who bills enough Medicare Part B professional services can take the hit. Check the QPP Participation Status Tool for each NPI / TIN, then check again when CMS posts final eligibility.
Hospital-based and non-patient-facing special statuses are common in anesthesia and often reweight Promoting Interoperability. That is not an excuse to skip Quality and Improvement Activities. It is a reason to report the categories that still count.
What we do about it
We are the billing firm, not a mystery registry with a 40-specialty dashboard. MIPS for our groups means: know who is eligible, pull what the anesthesia record already supports, keep the submission calendar from slipping, and not let a factory 'forget quality' while they chase claims.
- Eligibility check against current CMS status, not a guess
- Quality capture from the same charts we already bill AA, QZ, and QS from
- Improvement Activities that match how an anesthesia practice actually runs
- A human you can call when a measure or deadline moves
What we will not promise
We will not guarantee a positive payment adjustment. Those are tiny and funded by other people's penalties. We will not put a fake 100 on a file. We will tell you if you are not eligible, if a category is reweighted, or if the record cannot support a measure. Follow qpp.cms.gov for the year in front of you.
FAQ
Straight answers for practices comparing anesthesia billing companies.
What is the maximum MIPS Medicare penalty?
The statutory maximum negative payment adjustment is 9% of Medicare Part B covered professional services in the payment year. That maximum has been 9% since the 2022 payment year. Submitting nothing when you are eligible is how groups take the full cut.
Does a 2026 performance year hit 2026 payments?
No. There is a two-year lag. 2026 performance adjusts 2028 payments. Missing this year is a 2028 problem with your name on it.
Do CRNAs have to do MIPS?
CRNAs can be MIPS-eligible clinicians. Eligibility is by NPI / TIN and volume, not by job title. We check status instead of assuming.
Is MIPS included with billing?
MIPS support sits with the same US team that bills your claims. Talk to us about how it is scoped for your group. It is not a third vendor and a portal you never log into.
Related
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