The MIPS final regulation for 2022 has been made public. For small practices, there have been several adjustments that are quite beneficial. In addition to the usual modifications to measures, there are statutory amendments. We’ll go over the modifications to Traditional MIPS.
Clinicians Eligible for MIPS.
Two new types of eligible clinicians are available. With this modification, the list is now consistent with the categories of clinicians who can take part in alternative payment models.
- Promoting Interoperability for Clinical Social Workers will be reweighted to 0% for these practitioners.
- A specialist set of Quality Measures is accessible for this group.
- A specialized set of quality measures is offered for certified nurse midwives.
Raising the performance criterion for the first five years of the MIPS program is mandated by the Bipartisan Budget Act of 2018. 2022 marks the program’s sixth year. The performance threshold must be the “mean or median of the composite performance scores for all MIPS eligible professionals” from an earlier time period starting with year six onward. These levels ought to be roughly the same for the duration of the program because they are mandatory for the sixth year and subsequent years.
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The mean final score from the 2017 performance year/2019 MIPS payment year will be used by the Centers for Medicare & Medicaid Services to determine the performance threshold for the 2022 performance year/2024 payment year
75 points are the performance cutoff.
According to the law (Social Security Act 1848(q)(6)(D)(ii), an additional performance threshold must be set at either (1) the 25th percentile of the possible final scores range above the performance threshold or (2) the actual final scores for MIPS eligible clinicians with final scores at or above the performance threshold with respect to a prior period
89 points are the additional performance cutoff.
The actual 2017 final scores above 75 points fall into this quarter’s 25th percentile.
Weighting by Performance Category.
These performance category weights are in accordance with the law.
For small practices, the performance category weighting is the biggest difference. The category for “Promoting Interoperability” will automatically change in weight going ahead.
The remaining performance categories will have the following weights when Promoting Interoperability is reweighted:
- 40% quality
- Cost: 30%
- Improvement-related actions: 30%
Reweighting the performance criteria for Cost and Promoting Interoperability results in:
- 50% quality
- 50% of improvement efforts
When categories were reweighted in previous years, the weight tended to favour the Quality category. If that were to remain the same, it would be challenging for a small practise or speciality practise to meet the 75 point performance criteria, particularly in the absence of an electronic health record or with a dearth of appropriate quality indicators.
Quality Performance Categories.
Take away bonus points for high priority/outcome measures and end-to-end electronic reporting.
With few exclusions for tiny practises, get rid of the 3-point floor for scoring measures as of the 2023 performance period.
A total of 200 quality measures will be accessible for the 2022 performance period after the quality measure inventory has been updated.
substantial alterations to 87 currently used MIPS quality measures
Modifications to specialty sets
Measures that have been taken out of some speciality sets
13 quality measures are dropped
Four new quality measures have been added, including one new administrative claims measure:
Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions by Clinician and Clinician Group.
applying automatic reweighting to small practises and clinical social workers.
the following reporting required revisions:
To assist public health agencies (PHAs) through upcoming health threats and the protracted COVID-19 recovery process, the Public Health and Clinical Data Exchange objective’s reporting requirements should be revised.
Add a fourth exclusion for the Electronic Case Reporting measure, which will only be used in 2022.
New episode-based cost measures total five.
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Rectal and Colon Resection
Two long-term enhancement activities.
Seven new Improvement Activities will be added. Health equity will be covered by three of them.
15 activities will be changed. Eleven will deal with health equity. There will be a six-measure removal.The 2022 MIPS Final Rule modifications are described in general here. Resources for this last rule are available here.Check the QPP sites resources in mid-December to observe the modifications to the measures. Make sure your options are still available and take note of any differences so you can respond to them effectively.