2022 Changes to Traditional MIPS
On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) issued the Final Rule for the 2022 Medicare Physician Fee Schedule (PFS) which includes several changes to the Quality Payment Program (QPP). The Rule makes significant revisions to the existing MIPS program and outlines a timeframe for transitioning to the new MIPS Value Pathways (MVPs).
CMS has adopted substantial policy changes to traditional MIPS reporting in 2022:
MIPS Eligible Clinicians
Two new clinician types are added to the existing list of MIPS eligible clinicians beginning with the 2022 performance year:
- Clinical social workers
- Certified nurse-midwives
MIPS Performance Category Weight Changes
By law, the Quality and Cost performance categories must be equally weighted at 30% beginning with the 2022 performance period. The weights for the Promoting Interoperability (25%) and Improvement Activities (15%) categories will remain the same as 2021.
Minimum Performance Threshold and Payment Adjustments
CMS is required to establish 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 beginning with the 2022 performance year. The agency has finalized a minimum performance threshold of 75 MIPS points in 2022 (up from 60 MIPS points in 2021) which is the mean final score from the 2017 performance year. Next year clinicians will need to achieve a final MIPS score of at least 75 points to avoid any MIPS penalty.
An additional performance threshold of 89 points is established for exceptional performance. The 2022 performance year is the last year for an additional MIPS adjustment for exceptional performance.
The maximum payment adjustments for 2022 remain the same at +/- 9% and will be applied towards a clinician’s 2024 Medicare Part B payments for covered professional services. This means a MIPS eligible clinician who does not participate in MIPS in 2022 will receive a negative payment adjustment of -9% in 2024.
CMS finalized several changes to the MIPS Quality category.
- Data Completeness - MIPS eligible clinicians will continue to meet the current data completeness threshold of 70% (e.g., must report at least 70% of eligible cases for each Quality measure for the entire year, regardless of insurance) for the 2022 and 2023 performance periods.
- Quality Measure Scoring - Scoring updates will be applied to new measures and measures that do not meet case minimum and data completeness requirements, and measures that do not have a benchmark.
- New Quality measures - In 2022 a 7-point floor is established for the first performance period and a 5-point floor for the second performance period for new Quality measures.
- Beginning with the 2023 performance period:
- Measures with a benchmark - The 3-point floor is removed for measures that can be scored against a benchmark. These measures will receive 1-10 points.
- Measures without a benchmark - The 3-point floor is removed for measures without a benchmark (except small practices). These measures will receive 0 points (small practices will continue to earn 3 points).
- Measures that don’t meet case minimum requirements (20 cases) - The 3-point floor is removed (except small practices). These measures will earn 0 points (small practices will continue to earn 3 points).
- Bonus Points - 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.
- Scoring for Groups Reporting Claims Measures - CMS will only calculate a group-level Quality category 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).
- CMS Web Interface - The CMS Web Interface will be extended as a collection type and submission type in traditional MIPS for registered groups, virtual groups, and APM Entities with 25 or more clinicians for the 2022 performance period. It will continue to be a reporting option for Medicare Shared Savings Program ACOs through 2024.
- Quality Measures - There are 200 Quality measures available for the 2022 performance period. This includes substantive changes to 87 existing Quality measures, one new specialty measure set for certified nurse-midwives, four new Quality measures (including 1 new administrative claims measure), and removal of 15 existing Quality measures (two are applicable to Medicare Part B Claims only).
|Measures to be Removed||New Quality Measures||New Administrative Claims Measure|
#14 Age-Related Macular Degeneration (AMD): Dilated Macular Examination for Medicare Part B Claims type only
#481 - Intravesical Bacillus-Calmette Guerin for Non-muscle Invasive Bladder Cancer
Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
|#21 Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second-Generation Cephalosporin||#482 - Hemodialysis Vascular Access: Practitioner Level Long-term Catheter Rate|
|#23 Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients)||#483 - Person-Centered Primary Care Measure Patient-Reported Outcome Performance Measure (PCPCM PRO-PM)|
|#44 Coronary Artery Bypass Graft (CABG): Preoperative Beta-Blocker in Patients with Isolated CABG Surgery|
|#50 Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older for Medicare Part B Claims type only|
|#67 Hematology: Myelodysplastic Syndrome (MDS) and Acute Leukemias: Baseline Cytogenetic Testing Performed on Bone Marrow|
|#70 Hematology: Chronic Lymphocytic Leukemia (CLL): Baseline Flow Cytometry|
|#154 Falls: Risk Assessment|
|#195 Radiology: Stenosis Measurement in Carotid Imaging Reports|
|#225 Radiology: Reminder System for Screening Mammograms|
|#337 Psoriasis: Tuberculosis (TB) Prevention for Patients with Psoriasis, Psoriatic Arthritis and Rheumatoid Arthritis on a Biological Immune Response Modifier|
|#342 Pain Brought Under Control Within 48 Hours|
|#429 Pelvic Organ Prolapse: Preoperative Screening for Uterine Malignancy|
|#434 Proportion of Patients Sustaining a Ureter Injury at the Time of Pelvic Organ Prolapse Repair|
|#444 Medication Management for People with Asthma|
The Final Rule will add five newly developed episode-based Cost measures for the 2022 performance period.
- 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]
Improvement Activities (IA) Category
CMS will update the Improvement Activities inventory for the 2022 performance year, including adding seven new activities and modifying 15 current activities. Many of the changes pertain to health equity and standardizing language related to equity across the activities. There are six activities that will be removed from the IA inventory.
|Improvement Activities to be Removed||New Improvement Activities|
|IA_ BE_13 Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms||IA_AHE_8 - Create and Implement an Anti-Racism Plan (High)|
|IA_PSPA_11 - Participation in CAHPS or other supplemental questionnaire||IA_AHE_9 Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols (Medium)|
|IA_BE_17 - Use of tools to assist patient self-management||IA_BMH_11 - Implementation of a Trauma-Informed Care (TIC) Approach to Clinical Practice (Medium)|
|IA_BE_18 - Provide peer-led support for self-management.||IA_BMH_12 - Promoting Clinician Well-Being (High)|
|IA_BE_20 - Implementation of condition-specific chronic disease self-management support programs||IA_ERP_4 - Implementation of a Personal Protective Equipment (PPE) Plan (Medium)|
|IA_BE_21 - Improved practices that disseminate appropriate self-management materials||IA_ERP_5 - Implementation of a Laboratory Preparedness Plan (Medium)|
|IA_PSPA_33 - Application of CDC’s Training for Healthcare Providers on Lyme Disease (Medium)|
Promoting Interoperability (PI) Category
CMS will apply automatic re-weighting to the following, beginning with the 2022 performance period:
- Clinical social workers
- Small practices
Note there is no automatic re-weighting for certified nurse-midwives.
The following changes have also been adopted to the PI reporting requirements:
- Revises reporting requirements for the Public Health and Clinical Data Exchange objective to support public health agencies (PHAs) in future health threats and a long term COVID-19 recovery.
- CMS will require reporting of the Immunization Registry Reporting and Electronic Case Reporting (unless an exclusion can be claimed).
- The Public Health Registry Reporting, Clinical Data Registry Reporting, and Syndromic Surveillance Reporting measures will be optional and MIPS eligible clinicians could earn 5 bonus points if they report a “yes” response for any one of them. Note reporting more than one of these optional measures won’t result in more than 5 bonus points.
- Adopts 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 beginning with the 2022 performance period.
- Adds a fourth exclusion to the Electronic Case Reporting for the 2022 performance period only: Uses certified electronic health record technology (CEHRT) that isn’t certified to the electronic case reporting certification criterion prior to the start of the performance period they select in 2022.
- Modifies the Prevention of Information Blocking attestation statements.
Complex Patient Bonus
CMS will continue doubling the complex patient bonus for the 2021 MIPS performance year. These bonus points (capped at 10-points) will be added to the final score. The agency is also revising the complex patient bonus beginning with the 2022 MIPS performance year 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.
Some clinicians and practices are designated as facility-based and eligible for special scoring. CMS is adopting the following changes to facility-based measurement for the 2022 performance year:
- The MIPS Quality and Cost performance category scores will be based on the facility-based measurement scoring methodology unless a clinician or group receives a higher MIPS final score through another MIPS submission.
Redistributing Performance Category Weights for Small Practices
The Final Rule updates the redistribution policies for small practices. When the Promoting Interoperability performance category is re-weighted 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%.
In cases where both the Cost and the Promoting Interoperability performance categories are re-weighted the Quality and Improvement Activities categories will be equally weighted at 50%.