Covid-19

2022 Merit-based Incentive Program Final Rule

The 2022 final rule for MIPS has been released. There are some significantly helpful changes for small practices. There are statutory changes and the standard changes to measures. We will review the changes affecting Traditional MIPS.

MIPS Eligible Clinicians

There are two new eligible clinician types. This change aligns the list with clinician types eligible to participate in Alternative Payment Models.

  • Clinical Social Workers – Promoting Interoperability will be reweighted to 0% for these clinicians and there is a specialty set of Quality measures available for this group.
  • Certified Nurse Midwives – there is a specialty set of Quality measures available for this group.

Performance Thresholds

The Bipartisan Budget Act of 2018 requires raising the performance threshold during the first 5 years of the MIPS program. The program’s sixth year is 2022. The requirement for year six forward is the performance threshold must be the “mean or median of the composite performance scores for all MIPS eligible professionals” from a prior period. Because it is required for the sixth year and going forward these thresholds should remain about the same for the remainder of the program.

The Centers for Medicare & Medicaid Services is establishing the performance threshold for the 2022 performance year/2024 payment year using the mean final score from the 2017 performance year/2019 MIPS payment year.

  • The performance threshold is set at 75 points.

The statute requires that an additional performance threshold be set at (1) the 25th percentile of the range of possible final scores above the performance threshold or (2) the 25th percentile of the actual final scores for MIPS eligible clinicians with final scores at or above the performance threshold with respect to a prior period (Social Security Act § 1848(q)(6)(D)(ii)).

  • The additional performance threshold is set at 89 points.

o This is the 25th percentile of actual 2017 final scores above 75 points.

Performance Category Weighting

Per the statute the performance category weights are below.

The performance category weighting is the most significant change for small practices. Going forward the Promoting Interoperability category will automatically be reweighted.

When the Promoting Interoperability performance category is reweighted, the others will be weighted at:

  • Quality: 40%
  • Cost: 30%
  • Improvement activities: 30%

When both the Cost and Promoting Interoperability performance categories are reweighted:

  • Quality: 50%
  • Improvement activities: 50%

In prior years when categories were reweighted the weight tended to go to the Quality category. If that were to remain the same then it becomes difficult for a small practice or specialty practices to be able to reach the 75 point performance threshold especially with no Electronic Health Record or a limited number of Quality measures available. By evening out the reweighting it takes a significant burden off of these small and specialty practices.

Performance Categories

Quality

  • Remove end-to-end electronic reporting and high priority/outcome measure bonus points.
  • Remove the 3-point floor for scoring measures (with some exceptions for small practices), beginning with the 2023 performance period.
  • Update the quality measure inventory so that there will be a total of 200 quality measures available for the 2022 performance period.
  • Substantive changes to 87 existing MIPS quality measures
  • Changes to specialty sets
  • Removal of measures from specific specialty sets
  • Removal of 13 quality measures
  • Addition of 4 quality measures, including 1 new administrative claims measures:

–Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

  • CMS will only calculate a group-level quality score from Medicare Part B claims measures if the practice submitted data for another performance category as a group (signaling their intent to participate as a group).

Promoting Interoperability

  • Applying automatic reweighting to clinical social workers and small practices.
  • Revising reporting requirements in the following ways:
    • Revise reporting requirements for the Public Health and Clinical Data Exchange objective to support public health agencies (PHAs) during future health threats and the long-term COVID-19 recovery process.
    • Add a 4th exclusion for the Electronic Case Reporting measure, available for the 2022 performance period only.
    • Require MIPS eligible clinicians to attest to conducting an annual assessment of the High-Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides), beginning with the CY 2022 performance period.
    • Modify the Prevention of Information Blocking attestation statements to distinguish this from separate information blocking policies under the Office of the National Coordinator for Health Information Technology (ONC) requirements established in the 21st Century Cures Act Final Rule.

Cost

Five new Episode-based Cost Measures.

  • Two Procedural
    • Melanoma Resection
    • Colon and Rectal Resection
  • One Acute
  • Two Chronic

Improvement Activities

There will be seven new Improvement Activities. Three of them will address health equity.

Fifteen activities will be modified. Eleven of these will address health equity.

Six measures will be removed.

This is a general overview of the changes in the 2022 MIPS Final Rule. You can find resources for this final rule here.

In mid-December check the QPP pages resources to see the measure changes. Be sure your choices are still there and note any differences so you can address them appropriately. Please reach out to us at techassist@qsource.org if we can help you with your MIPS plan for 2022.

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