MIPS 2022 Final Rule
The MIPS 2022 Final Rule has been released and here is a breakdown of what you need to know about the program, overall and by category.
Overall:
For the 2022 performance year, to avoid a penalty eligible clinicians must earn a score of at least 75 points.
To earn exceptional performance, eligible clinicians must earn a score of 89 points.
At the time of attestation (i.e., in 2023 for the 2022 performance year) CMS has added a statement addressing the Prevention of Information Blocking. All attestors must select “yes” to be eligible for an incentive.
Quality:
Category weight will be worth 30% of the overall MIPS score.
The data completeness threshold will remain at 70%. This means you must report performance data (i.e., performance met or not met, or denominator exception) for at least 70% of the denominator-eligible encounters as outlined in the quality measure’s specification sheet.
· There are substantive changes to 87 existing MIPS quality measures.
o 9 of these measures won’t be eligible for a historical benchmark due to the extent of changes to the specification.
· Changes to specialty sets.
· Removal of measures from specific specialty sets.
· Removal of 13 quality measures.
· Addition of 4 quality measures, including 1 new administrative claims measure.
Measure benchmarks: After analyzing the available data, CMS determined there was no need to use performance benchmarks exclusively or to use a different baseline period (such as CY 2019) to create historical benchmarks. CMS will create historical benchmarks for the 2022 performance period, using data submitted for the 2020 performance period.
New measure scoring: Beginning in PY 2022: There will be a 7-point scoring floor for the first performance period and a 5-point scoring floor in its second performance period.
For example, a new measure available beginning with the 2022 performance period will earn 7-10 points in PY 2022 if a performance period benchmark can be created, and data completeness and case minimum criteria were met. The measure will earn 5 -10 points in PY 2023 if a performance period benchmark can be created, and data completeness and case minimum criteria were met.
Performance Period Benchmark Rules
The measure will earn 7 points in PY 2022 if no performance period benchmark can be
created, if data completeness and case minimum criteria were met.
The measure will earn 5 points in PY 2023 if no performance period benchmark can be created, if data completeness and case minimum criteria were met.
Data Completeness Rules
The measure will earn 0 points in PY 2022 and PY 2023 if data completeness isn’t met.
Exception: Small practices will continue to earn 3 points.
Case Minimum Criteria Rules
If case minimum requirements are not met in PY 2022, the measure will earn just 3 points.
And, a new policy for PY 2023, if case minimum requirements aren’t met, the measure will earn 0 points.
Exception: Small practices will continue to earn 3 points.
Improvement Activities:
Category weight remains at 15%
There has been removal of Improvement Activities.
In the case of an improvement activity for which there is a reason to believe that the continued collection raises possible patient safety concerns or is obsolete, CMS will promptly suspend the improvement activity and immediately notify clinicians and the public through the usual communication channels. CMS would then propose to remove or modify the improvement activity as appropriate in the next rulemaking cycle.
Improvement Activity Inventory is expanding. CMS is:
• Adding 7 new improvement activities, 3 of which are related to Promoting Health Equity.
• Modifying 15 current improvement activities, 11 of which address health equity.
• Removing 6 previously adopted improvement activities.
Promoting Interoperability:
Category weight remains at 25%
In addition to the existing special statuses/clinician types, automatic reweighting will apply for small practices and clinical social workers. If you qualify, this means the quality category will be worth at least 40% of you overall score.
CMS is modifying the reporting requirements for this objective and requiring MIPS eligible clinicians to report the following two measures (unless an exclusion can be claimed):
· Immunization Registry Reporting
· Electronic Case Reporting
Beginning with the 2022 performance period, the following measures are optional; clinicians, groups and virtual groups that report a “yes” response for any of these measures will earn 5 bonus points:
· Public Health Registry Reporting measure
· Clinical Data Registry Reporting measure
· Syndromic Surveillance Reporting measure
Reporting more than one of these optional measures will not result in more than 5 bonus points.
New required measure: MIPS eligible clinicians must attest to conducting an annual assessment of the High Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides).
Complex patient bonus: Because of the concerns of the direct and indirect effects of the COVID-19 PHE, CMS will continue to double the complex patient bonus available for the 2021 MIPS performance year/2023 MIPS payment year. These bonus points (capped at 10-points) would be added to the final score.
The revised complex patient bonus beginning with the 2022 MIPS performance by:
Limiting the bonus to clinicians who have a median or higher value for at least 1 of the 2 risk indicators (Hierarchical Condition Category score and proportion of patients dually eligible for Medicare and Medicaid benefits).
· Updating the formula to standardize the distribution of two risk indicators so that the policy can target clinicians who have a higher share of socially and/or medically complex patients.
· Increasing the bonus to a maximum of 10 points.
This bonus will be available to clinicians, groups, subgroups (beginning with the 2023 performance year), virtual groups or APM Entities that meet the criteria above and submit data for at least one performance category.
Cost:
Category weight will now be 30%
CMS is adding 5 newly developed episode-based cost measures into the MIPS cost performance category beginning with the 2022 performance period.
· 2 Procedural Measures:
o Melanoma Resection
o Colon and Rectal Resection
· 1 Acute Inpatient Measure:
o Sepsis
· 2 Chronic Condition Measures:
o Diabetes
o Asthma/Chronic Obstructive Pulmonary Disease [COPD]
Want all of the 2022 rule change details? You can comb through the full 2,414 pages here.
Want an expert to guide you to maximum points at an affordable monthly rate or answer any other questions? Contact us at 888-647-7247 or email hello@chirpybirdinc.com