Mark,
First let me thank you both for your consistent helpful participation on this board, for your longstanding efforts to help AC users in many areas, and for your years long work to understand the "incentive programs" and to explain how we can use AC to leverage our participation in those programs.
I have long advocated that docs should look annually at the potential penalties as well as the estimated costs of participation, and to make a calculation as to whether participation makes sense or not. In some years the amount of work seemed trivial (once I understood exactly what was involved) and in some years there were essentially automatic exclusions that I could honestly claim to avoid penalties. As I look back, this has worked for me; I am satisfied that I earned a decent amount through the incentives in the early years, and avoided penalties in later years.
I will also say the incentives were significant in the early years, but when MIPS came into play, I found them to no longer be a major consideration. As noted above, the bonuses are/were not guaranteed, either in amount or because you meet some metric. As Mark points out... the maximum achieved is under 2%. Aiming for that never made sense to me. My goal was always to "stay at 0" and avoid a penalty.
After 2020, I decided that enough was enough, and the amount of work required was simply too onerous, and so I would take my lumps, beginning in 2022-2023.
It turns out that any efforts to participate to avoid a penalty in 2021, 2022, or 2023 were unnecessary. This is the main point I am posting about. It turns out whether we asked for it or not, nearly all of us got an exemption and avoided the penalty. With one unfortunate exception: If you did not send in data for the years in question, you automatically are exempt from a penalty. If you DID participate and send in data, you do not get the exemption and still can end up with a penalty. (Yes, you can conceivably get a bonus, but as above, that is pretty unlikely and trivial).
What this means, is that CMS in its wisdom, unintentionally undercut the efforts of those who participated (and Mark) despite everyone's good intentions.
Again... the reason I titled this post as "mostly good news" is that for most, the lack of penalties in these 3 years is good. Unfortunately for some of those who did the work and paid the money to participate, it is not.
Of course now it is 2022, and our activities this year determine penalty/bonus for 2024. Who knows what the rules will be for that year. Once again, each person needs to make the calculation of the risk/cost of participation... with the added caveat that the rules may change AGAIN, so it is hard to know.
