The Key Takeaways from the MIPS 2022 Proposed Rule

We are about two months away from officially entering the MIPS 2022 performance period. And, CMS (Centers for Medicare and Medicaid Services) has released the Proposed Rule. The Medicare Physician Fee Schedule (PFS) for MIPS 2022 reporting is a document with propositions regarding changes in the upcoming year.

We had time until September 13, 2021, to comment on these propositions, and now we are waiting for the Final Rule. There were significant revisions about the MIPS program and a decent outlay for the transition to MIPS Value Pathways (MVPs).

How MIPS 2022 eligible clinicians or MIPS consultants on their behalf, can report data next year in light of the proposed rules, let’s follow-through.

Proposed Changes for MIPS 2022 Reporting

We can see many substantial changes that will affect the MIPS reporting for all clinicians, considering the existing program will be replaced by MVPs completely by 2027.

The List of Eligible MIPS Reporting Clinicians Extends

From 2022 onwards, two more clinician types would be able to report data to CMS to target MIPS incentives.  

• Clinical social workers

• Certified nurse-midwives

It is indeed a great step in the right direction as we could see more and more inclusivity. Now, more and more eligible clinicians can take part in quality payment programs (QPP).

The Weight Changes in the MIPS Performance Categories

Beginning from the MIPS 2022, CMS plans to equally weigh the MIPS Quality category and Cost category. They estimate them to be placed at 30%. However, Promoting Interoperability (PI) would remain at 25% as the last year. Similarly, Improvement Activities (IA) would stay at 15% as it was in MIPS 2021.

The Performance Thresholds and Minimum MIPS 2022 Performance Threshold

Minimum Performance Threshold

CMS is up to establish the MIPS performance threshold as per the mean or medium of the final score for all eligible clinicians of the previous year.

A total of 75 points are proposed as a minimum performance threshold for MIPS 2022. This figure is the mean total from the year 2017 MIPS performance year.

Last year, this number was 60 points for MIPS 2021 reporting.

Thus, if MIPS 2022 eligible clinicians want to avoid penalties, they must score at least 75 points.

Exceptional Performance Threshold

MIPS eligible clinicians would have to score a total of 85 points to meet the exceptional performance threshold. It is also to remember that this is the last year when clinicians can receive additional MIPS payment adjustments in this regard.

Penalty Threshold

The penalty threshold does not change in MIPS 2022 reporting period. Just like in MIPS 2021, eligible clinicians can receive up to 9% of positive or negative payment adjustments based on their performance.

Also, you would receive Medicare Part B payments for covered professional services in 2024.

Below are briefly described the changes for each MIPS performance category. 

Quality Performance Category 

The changes proposed for this category are:

• For MIPS 2022, eligible clinicians or their third-party vendor, a MIPS Qualified Registry must meet the 70% data completeness rule for this category. Moreover, the MIPS Quality data must comply with 70% of the eligible cases. 
• There would not be any bonus points for any of the data submitted in the MIPS 2022 Quality category. It applies for end-to-end (ETE) electronic reporting and reporting additional Outcome/High-priority measures. 
• CMS would only measure group-level Quality measures from Medicare Part B Claims measures only if they perform in another category as a group.
• There are 84 MIPS quality measures for which CMS has proposed substantial changes. 
• A new specialty measure set for Certified Nurse-Midwives has also been proposed by the agency. 

MIPS Cost Category 

We may have five new episode-based Cost measures for MIPS 2022 performance period. 

• 2 procedural measures

• 1 acute inpatient measure

• 2 chronic condition measures

Improvement Activity (IA) Performance Category 

• CMS has proposed to add seven new activities and modify 15 current activities for IA MIPS 2022 reporting. 
• Six improvement activities are also proposed to remove from the measure set. 
• CMS might also have the authority for MIPS 2022 to suspend any measure that poses any threat to patient safety. The status will be notified to medical practices, MIPS Qualified Registries, and the public through the regular communication channels.

Promoting Interoperability (PI) Performance Category 

Starting from the year 2022, CMS proposed to automatically reweigh this category for the following categories. 

• Clinical social workers

• Small practices

The reporting requirements for the Public Health and Clinical Data Exchange objective to support public health agencies (PHAs) would be revised. This measure is proposed in the context of the health threats and the COVID-19 recovery.

CMS would want the reporting Immunization Registry Reporting and Electronic Case Reporting (unless an exclusion case) for MIPS 2022.

MIPS eligible clinicians could receive five bonus points if they report measures related to:

• Public Health Registry Reporting

• Clinical Data Registry Reporting

• Syndromic Surveillance Reporting

CMS also plans to modify the measure related to public access to their healthcare information. 

CMS wants clinicians to attest to the annual assessment of the High-Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER guidelines). The attestation statement for the Prevention of Information Blocking might also be changed.