A MIPS Targeted Review is a formal process through which eligible clinicians or groups can request CMS to review their final MIPS performance feedback and associated payment adjustment if they believe there was an error in calculation or data attribution.
CMS opens the Targeted Review window annually after releasing Final MIPS Performance Feedback – typically in July for the preceding performance year.
For example:
2024 MIPS performance feedback is expected in July 2025
Targeted Review request period is open from July through early September 2025 (dates may vary slightly)
3. Why Would You Submit a MIPS Targeted Review?
There are several valid and CMS-recognized scenarios in which a Targeted Review is warranted. These typically fall into categories related to eligibility, data accuracy, scoring, or reweighting errors. Below is a more in-depth explanation of each common reason:
A. Data Submission Errors by Third-Party Vendors
Sometimes, clinicians rely on EHRs, Qualified Registries, QCDRs, billing companies, or clearinghouses to submit MIPS data on their behalf. Errors might occur due to:
Incomplete data transmission
Incorrect file formatting or mapping
Wrong provider identifiers (NPI or TIN)
Submitting data under the wrong performance year
These technical issues can result in missing categories, incomplete reporting, or even non-submission being recorded – all of which could lead to a negative or lower payment adjustment.
B. Incorrect NPI-TIN Attribution
MIPS scoring is done at the NPI/TIN combination level, and CMS might mistakenly:
Attribute a provider to the wrong TIN (especially if the provider switched practices mid-year)
Include performance data from a practice the provider no longer works at
Fail to link a provider’s correct TINs
This can distort performance results, especially if data from one TIN is inaccurate or incomplete, affecting the overall composite score.
C. Incorrect Special Status or Eligibility Designation
CMS provides automatic scoring advantages or exemptions to providers who qualify for special status, such as:
If CMS fails to recognize a provider’s correct status, the provider may:
Be required to report on more categories than they’re supposed to
Miss out on category reweighting benefits
Lose bonus points that could boost their final MIPS score
D. Errors in Performance Category Reweighting
Reweighting applies when:
A provider receives an approved hardship exemption (e.g., for Promoting Interoperability)
CMS auto-reweights a category based on special status
A clinician or group opts-in or is exempted from certain categories
If CMS miscalculates or fails to apply proper reweighting, it could unfairly:
Reduce the overall score
Introduce a zero-weighted category, pulling the score down
Misallocate weight to a poorly reported category
E. Discrepancies in Quality or Cost Score Calculations
Quality scores can be miscalculated if measure benchmarks are misapplied or if decile assignments are off
Cost performance could be skewed if CMS attributes patients or services inaccurately – especially for providers involved in multiple group practices or APMs
These errors can drastically alter the MIPS final score, sometimes causing a provider to drop below the performance threshold and face a negative adjustment.
F. Eligibility Changes Not Reflected in CMS Scoring
MIPS eligibility is checked periodically throughout the year. If a provider:
Becomes eligible or ineligible mid-year
Changes practice settings
Joins or leaves an Advanced Payment Model (APM)
CMS may fail to update their eligibility or scoring status accordingly. This could result in a provider being inappropriately scored, penalized, or excluded from bonus considerations.
4. What Information is Needed to Submit a Targeted Review?
Even a minor scoring error in your MIPS feedback can significantly affect your Medicare payment. If you think your score doesn’t reflect your performance, a MIPS Targeted Review may be your best recourse to protect your bottom line.
