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.
As we move into 2021 and beyond, we see CMS putting some real teeth into the Merit-based Incentive Payment System (MIPS) program. This is the first year where we see more than two percent incentives possible. Exemptions and exclusions are narrowing. Participants in other value-based programs are being forced into MIPS reporting because of higher thresholds for exclusion and elimination of other reporting options.
There has been much talk around MVPs in the CMS quality reporting arena. MVP means MIPS Value Pathway, and it’s a reporting framework that CMS is communicating as (a) the next evolution of MIPS and (b) a transition tool for getting to other alternative payment modules. As CMS continues to define and refine their vision of the MVPs, they have started to call the current framework 'traditional MIPS' to prepare for the inclusion of the MVP option. You’ll see this when you visit the QPP site. That said, how can MVPs affect MIPS?