MIPS 2022 – What’s likely to change
The Merit-based Incentive Payment System (MIPS) Proposed Rule for 2022 was released over the summer and gives strong clues as to what changes to expect within the program in the following year.
At Chirpy Bird, we’ve done our reading and want to share a summary of what we think is likely to change. The Final Rule is expected to release in late November.
1. Score thresholds will rise. The performance threshold is the total MIPS score at which neutral MIPS payment adjustments apply, scores above or below the threshold result in positive or negative adjustments respectively. CMS is incredibly likely to increase the performance threshold for the CY 2022 performance from 60 to 75 points. This means earning any fewer than 75 points will result in a financial penalty.
Exceptional performance threshold is mathematically proposed to be 89 points or higher.
2. Cost category points will increase. “Value” really is the product of Quality divided by Cost. As Cost counts more toward clinicians’ final score, we get a more accurate snapshot of the value of care they provide. In 2022, Cost, by law, is mandated to reach its maximum percentage of 30 percent of an eligible clinicians overall MIPS score. This means cost data, which is all tracked through administrative claims, is now worth the same as Quality.
3. Quality category points will decrease to compensate for Cost increasing. While the Cost and Quality category bear an inverse relationship, Quality remains one of the largest and most controllable MPS categories with a category weight of 30 percent for 2022. Having a consistent data capture process with the right quality measures at the beginning of the year for a practice will be critically important to its success.
4. Quality data completeness will rise. CMS has required quality data collection for all patients who qualify for the quality measure’s specifications, regardless of payer, and has historically increased the data completeness threshold each year. In both 2020 and 2021 the threshold was 70 percent. However, we anticipate this number rising to 80 percent in 2022. (That’s a lot of data to capture with little room for error.)
Scoring will move away from high-priority measure bonus points and 3-point floor in order to transition to a simplified scoring standard based on achievement.
5. Improvement Activities (IA) will evolve. Thanks in large part to the COVID pandemic, the IA category adds some much needed and highly relevant options under new sub-categories like “Achieving Health Equity,” “Emergency Response and Preparedness,” and “Behavioral and Mental Health.” With a category weight of 15 percent, IA is the easiest performance category to achieve maximum point potential. Make sure to keep an eye out for the removal of previously approved activities as the activities inventory is updated.
6. Promoting Interoperability (PI) will include updates to existing reporting requirements. PI will require patients to have access to their health records indefinitely and include reporting requirements to support data management of future health risks and long term COVID-19 recovery. PI will likely also include a new measure requiring clinicians to attest to conducting an annual SAFER Guide along with the annual Security Risk Analysis (SRA).
7. 2022 will be the most challenging year thus far. The MIPS program has historically had penalties in full force and incentives have been weaker than anticipated. However, hardships, exceptions, and category reweighing options have created opportunities for point and program success without too much effort. The shift in category points, combined with increased financial stakes will no doubt set the MIPS bar higher than years past.
