MIPS 2022: A Steep Climb Just to Avoid Penalty
It’s that time of year again….. Holidays and the MIPS 2022 “Final” Rule, which was issued by CMS on November 2, 2021. The Rule includes substantive revisions to the current MIPS program and provides a proposed timeframe for moving to the new MIPS Value Pathways (MVPs). After reviewing the MIPS 2022 Final Rule, we can say that 2022 will be a year where the guidance of a MIPS expert will be needed more than ever.
The climb to the first summit (avoiding a penalty) has an enhanced degree of difficulty as compared to prior years. Providers will need to review their MIPS strategy to ensure they can optimize their score and maximize the incentive potential as they prepare for the 6th year of MIPS. Let us give you the lay of this modified MIPS land and point at the most significant upcoming changes for MIPS 2022.
Traditional MIPS and MVP
The Quality Payment Program (QPP) replaced Meaningful Use and PQRS in 2017. Up until now, all eligible clinicians are required to participate in this program under one of the two tracks:
Merit based Incentive Payment System (MIPS)
Advanced Alternative Payment Models (Advanced APMs)
As CMS is laying the groundwork for the new MIPS Value Pathways (MVP) coming in 2023, it has introduced the term “Traditional MIPS” for the version of MIPS you’ve known and participated in so far. So if you encounter this term, don’t get thrown off. It is CMS’ way to try to prevent confusion in the future and make room for MVP on the QPP table.
2022 Performance Category Weight Change
By the law, the Quality and Cost performance categories must be equally weighted at 30% at the beginning of the 2022 performance period. The weights for the Promoting Interoperability (25%) and Improvement Activities (15%) categories will remain the same as 2021.
QUALITY
30%
PI
25%
IA
15%
COST
30%
Eligibility in 2022: New Eligible Clinicians Added
Two new MIPS eligible clinician types have been added for 2022 performance year to the 2021 list.
Clinical social workers (new)
Certified nurse-midwives (new)
Physicians
Nurse practitioner
Clinical nurse specialist
Certified registered nurse anesthetist
A group that includes such professionals
Physician assistant
Physical Therapists
Occupational Therapists
Qualified Speech Language Pathologists
Qualified Audiologists
Clinical Psychologists
Registered Dietitian or Nutrition Professionals
Steeper Performance Thresholds
Beginning with the 2022 Performance Year CMS is required to calculate a performance threshold that is either the mean or medium of the final MIPS scores for all MIPS eligible clinicians for a prior performance period. To that end, CMS has finalized a 2022 minimum performance threshold to avoid a penalty as a MIPS Composite Score of 75 points (up from 60 MIPS points in 2021). This score is the mean final score from the 2017 performance year.
The Exceptional Performance threshold will be increased to 89 points (up from 85 points in 2021).
2022 performance year will be the last year that CMS will provide an additional MIPS incentive for exceptional performance.
The maximum payment adjustments for 2022 have not changed and remain the same at +/- 9% and will be applied to a clinician’s 2024 Medicare Part B payments for covered professional services. Darena Solutions is working to update our MIPS Payment Adjustment Calculator to allow eligible clinicians to see the full range of positive to negative payment adjustments.
Quality Category
Data Completeness remains at 70% for 2022 and 2023.
Scoring for the Quality Measures
New Quality measures will have a 7-point floor for the first performance period and a 5-point floor for the second performance period.
No Bonus Points for E2E Reporting and Additional Outcome Measures– One of the significant items that will add to the degree of difficulty to meet or exceed the 75 point threshold is that bonus points will no longer be awarded in 2022 for end-to-end (ETE) electronic reporting and reporting additional Outcome/High-priority measures beyond the required measures.
CMS Web Interface Available for Groups of 25+ - This collection type and submission type will be maintained in traditional MIPS for registered groups, virtual groups, and APM Entities with 25 or more clinicians for the 2022 performance period. Additionally, this collection type will continue to be a reporting option for Medicare Shared Savings Program ACOs through 2024.
200 Quality Measures are available for the 2022 performance period.
Major changes to 87 existing Quality measures
1 new specialty measure set for certified nurse-midwives
4 new Quality measures (including 1 new administrative claims measure)
Removal of 15 existing Quality measures
NOTE: You need to earn your Quality category score via good performance and documentation without the assistance of End-to-End or additional High Priority bonus points. With a significant change in the Quality category measures and benchmarks, you’ll need to review your climbing strategy up the MIPS mountain beforehand.
Cost Category
5 brand-new episode-based Cost measures have been added for 2022.
2 procedural measures: Melanoma Resection, Colon and Rectal Resection
1 acute inpatient measure: Sepsis
2 chronic condition measures: Diabetes, Asthma/Chronic Obstructive Pulmonary Disease (COPD)
NOTE: If you do not have enough data to fulfill the Case Minimums for the Cost measures, CMS will reweight the Cost category to the Quality category.
Improvement Activities (IA) Category
Reporting Period is still a minimum of continuous 90-days
Group Reporting: For a Group submission, at least 50% of the providers must participate in the selected Improvement Activities for the same 90-day period (same as 2021).
Changes in IA Measures from the 2021 inventory :
7 new measures have been added
15 measures have been modified
6 measures have been removed
NOTE: IA still remains the easiest category to maximize the 15 points. You’ll need every single one of those points to make up for the lost scoring opportunities in the Quality category.
Promoting Interoperability (PI) Category
Automatic Reweighting: An interesting addition for 2022 is that CMS will apply automatic reweighting of the PI category for the following in addition to the hospital-based and non-patient-facing eligible clinicians and groups:
Clinical social workers (new)
Small practices (new)
Reporting Requirements: Changes have also been made to the PI reporting requirements:
Reduced some of the reporting burden requirements for the Public Health and Clinical Data Exchange objective to support public health agencies (PHAs).
CMS will require reporting of the Immunization Registry Reporting and Electronic Case Reporting (unless an exclusion can be claimed).
Reporting the measures for Clinical Data Registry, and Syndromic Surveillance will be optional, and MIPS eligible clinicians could earn an additional 5 bonus points if they report a “yes” response for any one of them.
SAFER Guides (new): For the 2022 performance period, CMS has added a new required measure called the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides). This measure requires MIPS eligible clinicians to attest to conducting an annual assessment of the SAFER Guides.
There is an addition of a fourth exclusion to the Electronic Case Reporting for the 2022 performance period only.
Modified the Prevention of Information Blocking attestation statements.
NOTE: With automatic reweighting for SMALL PRACTICES and more eligible clinicians, we urge you to proceed with caution. It might be easier to achieve a higher MIPS Composite score when submitting for both Quality and the PI categories than to get PI reweighted. It will require regular analysis to avoid the landmines in your path.
Connect with an experienced MIPS Guide to Assist in your ascent.
Complex Patient Bonus and Revisions
CMS did continue doubling the complex patient bonus for the 2021 MIPS performance year. These bonus points (maximum of 10-points) will be added to the final MIPS Composite Score. CMS is also revising the complex patient bonus beginning with MIPS 2022 MIPS by:
Limiting the bonus to clinicians who have a median or higher value for at least one of the two risk indicators (Hierarchical Condition Category (HCC) and proportion of patients dually eligible for Medicare and Medicaid benefits).
Updating the formula to standardize the distribution of two risk indicators so that the policy can target clinicians who have a higher share of socially and/or medically complex patients.
Increasing the bonus to a maximum of 10.0 points.
PI Category Weights Redistribution for Small Practices
The Final Rule updates the redistribution policies for small practices. When the Promoting Interoperability performance category is reweighted, the following category weights will apply:
Quality will be weighted at 40%.
Cost will be weighted at 30%.
Improvement Activities will be weighted at 30%.
Essentially, the 25 points for PI will have 10 points added to the 30 Quality points and 15 points added to the 15 points of the IA category.
Continued Flexibility and Bonuses for Small Practices (1-15 eligible clinicians)
Claims Option for Small Groups: Medicare Part B Claims will be available to Small Practice Groups for submitting MIPS data.
Double Points for IA: Small practices earn double the points for the Improvement Activities performance category
Data Completeness Not Met: Small practices will receive 3 points even if data completeness falls below 70% for Quality measures that do have a benchmark and meet the case minimum requirement. The other clinicians will receive 0 points.
Key Takeaways
The MIPS 2022 land is shifting and changing to make room for the new MIPS Value Pathways alongside Traditional MIPS and Advanced APMs. Resultantly, there are considerable changes to each of the performance categories. However, the increase of Performance Threshold to 75 points to avoid a penalty and the Exceptional Performance Threshold to 89 points are the biggest changes, given that 2022 MIPS performance year would be the last chance to earn the Exceptional Performance Bonus.
Don’t venture into the MIPS 2022 mountains without your MIPS sherpa.
Getting MIPS guidance is the smart approach and it’s easy. Schedule a free 15-minute conversation to get a headstart on your 2022 MIPS strategy.