Precision Value Based Management
You can add to the list above an additional penalty of 4% for 2019 and 7% for 2020 for failing to submit the Annual Wellness Visit (AWV) for at least 60% of your Medicare patients. BTW, you are paid an average of $148 per patient yet less than 10% of patients receive one nationally; hence the harsh penalties. Penalties can be viewed as the equivalent of claw backs as the money paid will be taken back by the payers.
Medicare, Medicaid and ACOs currently follow this system and private payers are following quickly.
The following contains links are to the 2019 CMS on Merit Based Incentive Payment System (MIPS), as well as an analysis of that report by an institutional leader.