Challenges to Earning a MIPS Incentive in 2022

Among the many challenges clinicians already face in 2022, the Merit-based Incentive Payment System (MIPS) adds to them by requiring participants to earn a score of 75 points (out of a possible 100) just to avoid a penalty on their 2024 Medicare reimbursements.

To help make it easier for small practices, CMS gives them the option to focus on fewer categories by offering to automatically re-weight the 25 points earned through the Promoting Interoperability (PI) category over to Quality. However, those who opt for this “benefit” will experience more of the challenges that the Quality category presents. You see, the ability to maximize one’s score in the Quality category is constrained by the substantive changes the Centers for Medicare and Medicaid Services (CMS) made to so many quality measures, thereby affecting their scoring potential. Additionally, the Cost category is now worth 30% of the overall MIPS score and remains a blind spot for many due to the way in which it is tracked.

So what can you do to ensure you avoid a penalty and hack the incentive territory of the program?

Start with Improvement Activities

Improvement Activities (IA) should earn each participant the full 15 points. Make sure you know how many activities to track and ensure you document your activities adequately. This category represents 20% of the minimum score required to avoid a penalty.

Reporting Quality is a MUST

This is the MIPS category that has the most potential for positive or negative movement. Selecting high-point potential quality measures based on your practice specialty and the tools and technology available to you will help make the most from this category. Take extra care to familiarize yourself with the substantive changes CMS made to dozens of measures. Be careful in your selection, as many measures do not have benchmarks or have a reduced scoring potential for various reasons. A smart combination of measures, even if they are new for you this year will be better than leaning on old options. Although the category requires six measures to be reported, we recommend submitting data for as many quality measures as possible to support avoiding that penalty. When it comes to data collection, our philosophy is to collect measure data for every patient, every encounter, every time.

Consider Reporting Promoting Interoperability

Even for small practices that have the option to reweight this category, we suggest using your EHR to collect data for your most robust 90-day reporting period. This can be done by leveraging certified health IT to introduce specific data-collecting workflows to staff and make tracking this category’s objectives and measures more seamless and less resource-intensive. Be aware of how to meet all measures within your EHR. The points available through this category will likely help you close any gaps made from the reduced-point potential in Quality.

Be Mindful of Cost

CMS tracks this category via administrative claims, which is why its score feels like a blind spot to many. Considering Cost makes up 30% of the overall score for 2022, it is important to look at your historic data and to educate yourself on the episode measures that could affect your practice’s score. These two efforts can make a HUGE difference. At Chirpy Bird, we educate our clients and provide non-clinical strategies to help navigate the Cost category so that practices are not over-burdened for care they did not directly provide.

Regardless of how you get there, avoiding a penalty and earning an incentive will require a significant mind-shift in HOW to achieve an incentive-level score this year.

We are here to help!

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Dermatology and Promoting Interoperability: Tips for Your Practice

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The Case for 2022 MIPS Participation