The Expected Changes for MIPS 2022 Performance Evaluation

MIPS (Merit-based Incentive Payment System) was introduced as a part of the Quality Payment Program (QPP) for the Medicare Part B healthcare providers. It was so they could get compensated based on their value-based healthcare services.

Each year, there are changes in the rules, measures, and requirements for each category of MIPS. Let’s see what 2022 has in store.

Changes in the MIPS 2022 Performance Evaluation

We can look forward to several changes in each performance category. Such as:

Expansion of the Clinicians Type to Participants 

In 2022, two new clinician types will be eligible for MIPS participation.

These are:

• Certified nurse-midwives

• Clinical social workers

Weightage

In 2022, the weightage of each category will change. The new percentages for each performance category are:

• Quality = 30%

• Cost = 30%

• Promoting Interoperability (PI) = 25%

• Improvement Activities (IA) = 15%

MIPS 2022 Minimum Performance Threshold

The minimum performance threshold for MIPS in 2022 is 75. It means that participants need to get at least 75 points to pass the evaluation and avoid a penalty. The number has actually increased because it was 60 points in 2021.

In addition to that, 89 points are the new exceptional performance threshold. And 2022 will be the last year for an additional MIPS performance adjustment for Exceptional Performance.

Payment Adjustment Percentage 

The payment adjustment for MIPS 2022 will be the same as before. A positive 9% if you pass the evaluation and a negative 9% if you fail or do not participate. This positive or negative adjustment will apply to the healthcare provider’s 2024 Medicare part B payments.

Changes In the Performance Categories

Now let’s look at the different performance categories and what changes they have for us in the MIPS 2022 evaluation.

Quality

There are several changes in the quality category, like

Completeness of Data

Clinicians who are MIPS eligible will continue to meet the existing data completeness and submission threshold, i.e., 70%. It is applicable for both the 2022 and 2023 performance years.

Bonus Points

There will be no bonus points for End-To-End (ETE) Electronic Reporting and for reporting additional High Priority/Outcome measures in 2022.

Group Scoring For Claim Measures

CMS will only calculate a group’s quality measures score from the Medicare part B claims measures if they submitted data for another category as a group too.

CMS Web Interface

For the coming year, CMS has allowed groups, virtual groups, and APM Entities with 25 or more healthcare providers to submit data to their web interface. It is for the traditional MIPS 2022 evaluation.

Quality Measures

There are 200 quality measures available for the MIPS 2022 performance period. These include:

• The edited and revised already-existing 87 measures

• A new specialty measure for the nurse-midwives

• And four new quality measures, including one administrative claims measure

• There has also been the removal of 15 pre-existing quality measures, two of which were applicable for the Medicare part B claims.

Scoring of Quality Measures

The scoring system for quality measures has been updated. Due to this, other rules and regulations have also undergone revisions.

Such as:

• New measures will have a 7-point floor for the first performance period and a 5-point floor for the second performance period.

• Measures without any benchmarks will have their 3-point floor removed in MIPS 2022. They will receive no points unless a small practice is submitting them, who will still get the 3 points.

• There are 20 cases of measures that don’t meet the case minimum and data requirements in 2022. Their 3-point floor has also gotten removed, and unless it’s a small practice, these measures will be worth no points.

Cost

The cost category will have five new episode-based measures added in 2022. These are:

• Procedural Measures

There are two additional procedural measures for the cost category, which are

1. Melanoma Resection
2. Colon and Rectal Resection

• Chronic Condition Measures

There are two additional chronic condition measures as well for the cost category. These are:

1. Asthma/Chronic Obstructive Pulmonary Disease
2. Diabetes

• Acute Inpatient Measure

There is one additional acute inpatient measure, and it is for patients suffering from Sepsis.

Promoting Interoperability (PI)

Like all the other categories, PI has also made some changes in its reporting requirements.

• Examining Reporting Requirements

The reporting requirements for the Public Health and Clinical Data Exchange Objective will be revised. This is so they can aid public health agencies (PHAs) in future emergencies and the COVID-19 recovery period.

Plus, some things are compulsory now, while some have been deemed optional. Such as:

• Submitting data for the Electronic Case Reporting and Immunization Registry Reporting has been made compulsory. Clinicians can only be exempt from these if they have received approval for an exclusion.

• Data submissions for the Syndromic Surveillance Reporting, Clinical Data Registry Reporting, and the Public Health Registry Reporting have been made optional. The clinicians who respond to any one of these will receive five bonus points. Also, submitting data for all of them will not result in any additional bonus points, as only one is necessary.

• Safety Assurance Factors for EHR Resilience Guides (SAFER Guides)

The Safety Assurance Factors for EHR Resilience Guides is a new measure in MIPS 2022 reporting. It requires MIPS 2022 eligible clinicians to submit their data to an annual SAFER Guides assessment.  

• Addition of Fourth Exclusion to ECR

A fourth exclusion has been added to the Electronic Case Reporting Section for the coming performance year. It is that “reporting clinicians should use updated certified electronic health record technology (CEHRT) that meets the criteria set for the MIPS 2022 evaluation.”

• Preventing Information Blocks

For MIPS 2022, there have been changes in the attestation statements, so no information could be blocked or kept from being delivered.

Improvement Activities (IA)

CMS has updated the IA for MIPS 2022 reporting by adding seven new activities and making changes in 15 of the currently-existing ones. Many of the changes deal with improving health equity in the healthcare system, which is why there will be a removal of six measures from the IA inventory along with the above-mentioned changes.  

The Final Rule

With the introduction of The Final Rule, CMS will be able to suspend activities that:

• Don’t need to be continued because they are outdated.

• Shouldn’t be continued because they are detrimental for patients rather than beneficial.

In such cases, CMS will inform both clinicians and the public of such a change, and then it will be decided if the activity should be modified or removed for MIPS 2022.