Healthmonix Advisor

Discover the game-changing impact of the 2022 MIPS Final Score Preview period as we delve into the long-awaited return of Cost category scores after 3 years. The implications for providers' total MIPS scores are profound, and we have the insights you need to navigate this transformative shift.

Last week, CMS confirmed that 2022 MIPS scores for eligible providers will include the Cost performance category. Per CMS: 

“For the 2020 and 2021 performance periods, CMS reweighted the MIPS Cost performance category to 0% as a result of the COVID-19 public health emergency (PHE). For the 2022 performance period/2024 MIPS payment year (hereafter written as “2022 performance period”), CMS conducted an empirical analysis to assess whether any or all cost measures were continually impacted by the COVID-19 PHE and, if so, whether it would be appropriate for CMS to reweight the Cost performance category again under § 414.1380(c)(2) or to exclude any individual cost measures.  

Read on to learn more about how these changes may affect your MIPS participation and payment year.

Explore the options for 2023 and look forward to 2024! 

In 2023, MIPS Value Pathways (MVPs)present a new and challenging reporting option for many providers. There are twelve available MVPs focused on specialties such as Emergency Medicine, Oncology, Hematology, Cardiology, Internal Medicine, Family Medicine, Rheumatology, Neurology, Neurosurgical, Vascular Surgery, Orthopedic Surgery, Nephrology, Anesthesiology, Preventive Medicine, and Geriatrics. 

While MVPs can be helpful for reporting, they also pose some challenges.

The Centers for Medicare and Medicaid Services (CMS) have initiated the development of a Universal Foundation of quality measures to improve healthcare quality and transform care.

CMS operates more than 20 quality programs, each with its own set of quality measures. The lack of alignment across these programs has contributed to challenges for clinicians, facilities, and health insurers in prioritizing meaningful outcomes for patients.

By identifying CMS's priority areas for measurement and revealing gaps, the Universal Foundation will evolve over time, with the intent of reducing provider burden and improving patient outcomes.

If you are a dermatology practice, you probably breathed a sigh of relief when the Centers for Medicare & Medicaid Services (CMS) announced that dermatologists, along with many other specialists, would no longer be attributed patients for the Total per Capita Cost (TPCC) measure, as part of the Cost component of the Merit-based Incentive Payment System (MIPS).  However, in 2022, CMS introduced a Melanoma Resection Cost measure that is attributed to those specialists that perform these resections. So the Cost category is back for many dermatologists.  Even if this is the only Cost measure that is attributed to your practice, it is worth 30 of your total 100 MIPS points - as much as all your Quality measures combined!

With the release of the 2023 PFS Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized most of the proposed changes for the QPP / Merit-based Incentive Payment System (MIPS) program that had been released in the Proposed Rule last July.  

We are seeing that while the payment threshold is holding at 75 points, it can be tougher to achieve that threshold score with the changes in the program for 2023.

Electronic health record (EHR) companies have their single biggest technical update to complete by September 2023, as announced in a recent a meeting with the Deputy National Coordinator of Health Information Technology.  All EHR enhancements that are required to comply with the 2015 Cures Act standards must be completed by September 2023.   All data that is shared must be normalized by that time and EHR technology vendors are required to certify with real world testing.  

If you are managing a Medicare Shared Savings Program accountable care organization (MSSP ACO), you have heard the mandate from the Centers for Medicare & Medicaid Services (CMS) to move to eCQM/CQM reporting, replacing the Web Interface reporting.  You may also be aware of the significant pushback that ACOs, collectively and independently, have provided to CMS.  At this year’s fall National Association of ACOs (NAACOS) conference, the tenor changed to accepting the move, optional in 2022 through 2024, but required in 2025.

As you report your MIPS data, it can feel like a lot of work with little ROI for the last two years. But wait. Sometimes we need to step back and evaluate the bigger picture. While we often focus on "getting the job done", there are changes in the healthcare economy that are occurring that are strategic.

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Physician Fee Schedule (PFS) Final Rule which governs MIPS and other quality payment programs. Anticipated changes were made to MIPS, making the program more challenging in 2022 and signaling additional changes to the program in coming years.