It’s difficult to believe, but 2022 is just around the corner – and with it a new set of MIPS (Merit-based Incentive Payment System) updates to digest and incorporate into your MIPS strategy. MIPS is “one way to participate in the Quality Payment Program [in which] you earn a payment adjustment for Part B covered professional services based on our evaluation of your performance,” according to CMS.
While adjusting to each year’s new MIPS rules is an annual challenge many providers are already familiar with, performance year 2022 will bring several changes that are more significant than those seen in previous years. Providers’ ability to successfully adapt to these changes will determine whether CMS adjusts their payment reimbursement positively or negatively.
Changes to the MIPS Program for Performance Year 2022
There are three significant updates to MIPS for the 2022 performance year that are likely to impact provider scores and associated payment adjustments.
1. Removal of the Extreme and Uncontrollable Circumstances (EUC) Policy
First, CMS has NOT indicated that they plan to continue the reporting flexibilities enacted due to the ongoing COVID-19 pandemic. Providers will no longer have the option of requesting reweighting of one or multiple scoring categories under the Extreme and Uncontrollable Circumstances (EUC) policy. Many practices and providers used the COVID-19 EUC hardship as a “get out of jail free” card for the 2020 and/or 2021 performance years, and with good reason. COVID-19 wreaked havoc in direct and indirect ways throughout healthcare.
However, when practices are not actively working on MIPS, their MIPS performance monitoring inevitably falls by the wayside. We are seeing performance on MIPS quality measures drop significantly, which will lead to lower overall scores for the 2022 performance period – especially if practices do not act soon to improve performance prior to the start of the performance period on January 1. The MIPS Quality performance category requires a full 12 of data submission, so the highest performers will be those who start the year off strong.
2. Increased Performance Thresholds
The second notable change for MIPS in 2022 is increased performance thresholds. To avoid a negative payment adjustment in 2024, providers will need to score at least 75 points in MIPS in 2022. To achieve exceptional performer status and earn a share of that bonus pool, providers will need to score at least 89 points. To put this in perspective, remember that in 2017 – the first MIPS performance period – the performance threshold was 3 points, and the exceptional performer threshold was 75 points. This means that the same score which was considered exceptional in 2017 is now the bare minimum to avoid a penalty.
While CMS has been gradually building to this point, many providers will still be unprepared for the stark reality of MIPS as it was originally designed – a program that puts providers in competition with each other. This is especially true for those providers who have used the COVID-19 EUC for the last two years, and they have let their MIPS efforts slide.
3. Quality and Cost Categories Will Now Be Rated Equally
The third and final major update is that – for the first time since the MIPS program’s inception – the Quality and Cost categories will be weighted equally at 30% each. This change was mandated in the original Medicare Access and Chip Reauthorization Act of 2015 (MACRA) legislation. CMS does not have the authority to adjust this change without further rulemaking, but it could not come at a worse time for providers. Cost is the least understood MIPS category, and for good reason. Not only do providers not actively report data (as CMS obtains it from administrative claims), the specifications behind measure calculation, attribution, and scoring are extremely difficult for non-mathematicians to fully grasp.
As mentioned above, not only are many providers returning to the MIPS world after COVID-19, they are re-entering a program that judges their performance in areas that are not fully under their control. Many cost measures include the provision of services by all providers, not just those in the reporting practice. Additionally, providers are not provided relevant data on which to act before or during the performance period. Thanks to COVID-19 and the automatic reweighting of the cost category for 2020, providers will not even have practice-specific historical feedback to help guide their efforts moving forward. This perfect storm will undoubtedly result in a significant drop of MIPS Final Scores across the board for 2022.
While these are some of the most significant changes to MIPS for the 2022 performance year, they are by no means the only ones contained in the full, 1,747-page Proposed 2022 MIPS Final Rule. While understanding all these rule changes can be complex, there are best practices medical organizations of all kinds can follow to help improve their MIPS performance. We have compiled a checklist of five actions you can take to prepare for 2022.
5 Steps to Improve MIPS Performance for Performance Year 2022
1. Determine Which MIPS Data You Need to Submit
While most providers who have participated in MIPS before are likely to, by now, be somewhat familiar with the different reporting categories, it bears revisiting what providers are required to report for each MIPS performance year. Just as there are major program changes each year, there are also smaller, category and measure-specific changes that must be reviewed. Do not make the mistake of assuming that all measures you reported previously are still available in 2022, or that the specifications for those measures have remained static. Use the QPP Resource Library to dive into those specifications for Quality, Improvement Activities, and Promoting Interoperability to make sure you are completely and accurately reporting your data. This will maximize your chances of scoring well and avoiding potential headaches if you are audited in the future.
2. Determine Which MIPS Framework You Should Use to Submit Your Data
The next step is to determine which framework your organization will use to submit your data to CMS. When MIPS started in 2017, no one would have said the MIPS reporting framework was simple, but at least there was only one option. Now you have several frameworks to choose from, and there are important distinctions and requirements for each of them. These frameworks include Traditional MIPS as you have known it all along, APM Performance Pathway (APP) for providers who participate via MIPS APMs, or the MIPS Value Pathways (MVPs) which are designed around specific populations of patients. This expansion of options is a double-edged sword because with increased flexibility comes increased complexity. Success in any framework will be tied to understanding the associated pros and cons specific to your practice circumstances.
3. Research and Understand Changes to MIPS Scoring for 2022
As discussed at length in the above section [Changes to MIPS Quality Measures for Performance Year 2022], there is no shortage of program level changes to MIPS for the 2022 performance year that providers should be aware of. However, there are category scoring changes to contend with as well.
Perhaps the most significant is the proposed elimination of end-to-end electronic reporting and high-priority bonus points in the quality category. If passed in the final rule, this would make it much more difficult for providers to score above the Exceptional Performer threshold. Practices that have been strategically using quality bonus points to their advantage for the last five years to maximize their quality score can expect to see their category score drop by up to 12 points in 2022. While negative feedback from providers and provider advocate groups may be enough to prevent this change from being implemented in this year’s rule, once CMS proposes a change like this, it does usually get implemented, even if delayed by a year or two.
Also, in the quality category, CMS is proposing to remove the 3-point floor for individual measure scoring for practices with more than 15 providers. In the cost category, CMS has proposed five new episode-based measures for 2022. When you combine these scoring changes with the shift to equal weighting for Quality and Cost, providers can no longer assume that their MIPS score will stay the same – and be high enough to avoid penalty – even if their individual measure performance remains stable.
Due to this, MIPS Final Scores are likely to be significantly lower than in years past and given that performance thresholds are rising to new highs, scores that previously earned incentives may now be subject to penalties. Providers who do not evaluate their past MIPS performance against new scoring standards will be in for a rude awakening when they go to report in early 2023. And at that point, it will be too late to act. We recommend you begin researching as much as you can about the 2022 proposed rule scoring changes for MIPS, and keep an eye out for the final rule – it is likely to be published in late November or early December 2021.
4. Evaluate Your Projected MIPS Performance and Adjust Your Strategy
Armed with the insights from your enhanced understanding of the MIPS changes proposed for 2022, it is time to take a critical look at your organization’s performance. Will your organization be able to continue scoring at a high enough level to avoid being penalized? Will your organization have a difficult time adjusting to a more heavily weighted cost category? While such reflections can be both difficult and time-consuming, they are of the utmost importance. Participating in MIPS is a long game. Changes to EHR documentation, workflows, and strategies take time to implement and even longer to affect changes in your performance rates. Rewards for your efforts to improve your MIPS performance will come at least a year after your MIPS performance data is submitted. It is crucial that your organization begins optimizing and updating its operational and reporting strategy for MIPS as soon as possible to get ahead of increasingly demanding and competitive MIPS requirements. Choosing to wait can be costly in the future.
5. Hire a MIPS Expert
Medical Advantage’s MIPS consulting team understands how overwhelming MIPS can be because we have been in your shoes. We know how medical professionals have their hands full with the day-to-day activities of tending to patients and running their practice. It is difficult to shoehorn even the smallest additional responsibility into your day – let alone make the time to understand a complex and ever-shifting regulatory program, and then implement operational adjustments based on those findings.
Understanding and implementing MIPS policy is a full-time job – our full-time job. We have worked with hundreds of organizations large and small to improve MIPS scores, avoid penalties, reap incentives, and reduce administrative burden and stress. If ever there was a time to reach out for assistance with MIPS, it is now.
To find out more about how we can help, contact our MIPS consulting team today.