Impact of COVID-19 Efforts on Payment Adjustments in MIPS 2022

MIPS 2022 has been the payment adjustment year for MIPS 2020 reporting – the drastic phase for providers which has influenced the MIPS reporting a lot.

CMS has made simple rules and planned every event in MIPS reporting from the beginning. For MIPS 2021 as a performance year, the respective payment adjustment year was CY 2022. However, CMS has provided the relevant MIPS 2020 final score to all the participants long before entering 2022. This MIPS final score-assigning process was done in August 2021. And almost this is the same pattern for every MIPS program. Every year providers enter a new MIPS performance year while receiving MIPS final score for the previous year. Alongside this, the same CY is marked as a payment year for some previous QPP MIPS reporting. Thus, MIPS 2022 payment year is aligned with MIPS 2020 performance year.

If we overview the MIPS reporting difficulties of providers at that time, we have COVID-19 as the major problem. The world was fighting hard with the health disasters spread by this deadly pandemic. Nobody was in a strong position financially. So, it was healthcare providers, who got the most effect from it. Thus, CMS has considered COVID-19 challenges for providers. And given relative relaxation to them. Thus, CMS has tried to save them from the consequences of their performance in the MIPS 2022 payment year.

Let’s have an overview of COVID-19-related initiatives by CMS to cope with MIPS 2022 adjustments.

Extension of EUC Policy; Great Favor by CMS

EUC stands for ‘extreme and uncontrollable circumstances’. The EUC policy is a way CMS has allowed its participants to deal with poor performance. This average or below average performance can be due to any unwanted problem just as COVID-19. Thus, CMS accepts EUC applications from MIPS participants and evaluates their circumstances. If CMS finds them worth as per the pre-set criterion, their four performance categories are automatically reweighted.

Usually, CMS opens the application phase of the EUC application for a limited time. It closes the application portal by the beginning of the next CY. For instance, MIPS 2020 participants have a deadline for claiming their exception application till January 1, 2021. However, CMS has extended the deadline to March 31, 2021. It is more likely that many participants will get the negative adjustment in MIPS 2022 PA. So, by the extension of the EUC policy’s deadline, CMS has limited the penalty chances for providers.

MIPS 2022 Payment Adjustments Flexibilities; COVID-19 relief efforts

CMS has put forth multiple COVID-19 relief efforts. All of them have introduced flexible ways for impacting the MIPS 2022 payment adjustments. Some of these general flexibilities are mentioned below:

Complex Patient Bonus

MIPS performance year 2020 has a unique patient bonus option. An eligible participant takes the advantage of dealing with complex patients. For MIPS 22022 adjustments, CMS has declared to double the bonus points for such participants. This implies that eligible providers secure a maximum of 10 bonus points. CMS will automatically have already added them to their MIPS final scores in CY 2021.

Reweighting of MIPS Cost Categories

The cost category constitutes 15% of the MIPS final score. However, CMS has reduced the cost category contribution to zero for MIPS 2020 PY. Alongside, it has strategically distributed that 15% weight to the other three MIPS performance categories. 

Attention!

One must keep this fact in mind the MIPS 2022 adjustment using the EUC application is different from MIPS cost category reweighting.

This means that MIPS EUC policy applies to individual participants dealing with such circumstances. However, this cost category automating reweighting to zero is equally implementable for all.

Accounting Budget Neutrality and Scaling Factors

CMS has to take care of MIPS budget neutrality. Therefore, they somehow maintain the proportion of MIPS penalties and MIPS incentives. However, due to COVID-19, it was more likely that providers will bear the burden of -ve MIPS 2022 adjustments. Therefore, CMS has decided to overcome the budget neutrality issue. We have a factor named the ‘scaling factor’ that plays the role of budget neutrality in MIPS payment. The MIPS scaling factor has a value somewhere between 0 to 3. However, it is the distribution of MIPS final scoring that governs the exact amount of scaling factor.

Conclusion

QPP MIPS 2022 payment adjustment for all participants is influenced a lot by the COVID-19-related flexibility provided by CMS. The federal government has done every possible step to save the MIPS participant from negative payment adjustments. MIPS EUC policy and cost category reweighting along with special status assigning are great options to reduce reporting burden. Alongside, CMS is controlling budget neutrality with a scaling factor every year.