The MIPS 2022 Medicare Physician Fee Schedule (PFS) Final Rule was published by the Centers for Medicare and Medicaid Services (CMS) on November 2, 2021. The Quality Payment Program (QPP) is altered by the Rule in a number of ways, including modifications to the current MIPS program and a deadline for implementing the new MIPS Value Pathway (MVPs).
The MIPS Blog outlines some of the most important lessons regarding the significant policy changes that CMS has implemented for traditional MIPS reporting in 2022 and subsequent years.
Clinicians eligible for MIPS
Clinical social workers and certified nurse-midwives have been introduced as two new sorts of clinicians to the list already in existence.
Changes to the MIPS Performance Category Weights:
The Quality and Cost performance categories must each have a 30% weighting starting with the 2022 performance period. Promoting Interoperability and Improvement Activities continue to be weighted at 25% and 15%, respectively, as of 2021.
Beginning with the performance year in 2022, CMS must establish a performance criterion for a previous performance period that is equal to the mean or median of the final MIPS scores for all eligible doctors.
For 2022, a performance threshold of at least 75 MIPS points has been set.
The final year for this additional MIPS adjustment is 2022, and a new performance threshold of 89 points is established for exceptional performance.
The maximum payment adjustments for 2022 remain unchanged at plus or minus 9% and will be applied towards a clinician’s 2024 Medicare Part B payments for covered professional services.
Quality Class –
Data Completeness, Quality Measure Scoring, Bonus Points, Scoring for Groups Reporting Claims Measures, CMS Web Interface, and Quality Measures are the six elements that CMS has finalized improvements to in this area.
Cost Category: For the 2022 performance period, the Final Rule introduces 5 newly created episode-based cost metrics.
Category of Improvement Activities
The Improvement Activities inventory has been updated for the 2022 performance year, introducing 7 new activities and changing 15 already existing ones.
Category for Promoting Interoperability
Clinical social workers and small practices will both be subject to automatic reweighting by CMS starting with the 2022 performance period.
Complicated Patient Incentive:
For the 2021 performance year, the complex patient bonus will continue to double.
Measurement at Facilities
The facility-based measurement scoring methodology will be used to calculate the MIPS Quality and Cost performance category scores until a clinician or group achieves a higher MIPS final score as a result of another MIPS submission.
Changing the Weights of Performance Categories for Small Practices
Quality will be given a 40% weighting when the Promoting Interoperability performance category is reweighted, Cost a 30% weighting, Improvement Activities a 30% weighting, and, in the event that both the Cost and the Promoting Interoperability performance categories are reweighted, Quality and Improvement Activities will be given an equal 50% weighting.
The California Medical Association asserts that even if a doctor or small practice has included quality data codes on their 2021 Medicare claims, they will still need to submit a 2021 MIPS Hardship Extreme and Uncontrollable Circumstances (EUC) exception in order to avoid a 2023 payment adjustment and be exempt from the 2021 MIPS program.
Additionally, if a group practice that generally takes part in MIPS as a whole has not yet submitted data for 2021, the automatic EUC policy will be applied to the group’s individual doctors. To prevent a 2023 payment modification, the group must apply for the EUC if any 2021 data have been submitted. Accordingly, the automatic EUC will apply to the physician if the practice or doctor has not yet provided any 2021 MIPS performance data.
