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.
For 2022, key takeaways for the Traditional MIPS program can be seen on our MIPS 2022 fact sheet, and in our 2022 Final Rule Webinar - Finally Seeing MIPS ROI Despite Harder Program.
Some observations:
- Many more MIPS participants will see penalties in 2022. The thresholds for avoiding the penalty have gone up, and many of the additional bonus points that have been included in scores in prior years are being removed. CMS is removing several scoring mechanisms that created what some call “score inflation” which has occurred over the last few years. These include end-to-end bonuses, high priority and outcome measure bonuses, and the awarding of complex patient bonuses to nearly all providers. So between the higher threshold and lower number of points achievable by many, it will be a challenging year.
- Since there will be more providers unable to avoid a penalty, and this is a budget-neutral program, we do expect to see a significant increase in incentives. We’ve been in this position in the past (as we entered 2020 and 2021), but barring the extension of the public health emergency, we see that penalties and incentives will be much more tangible for reporting in 2022.
- New in 2022, providers will be rewarded for reporting first and second year Quality measures. We applaud this action on CMS’s part. In the past, we have implemented many new measures that providers have not reported, due to the fact that benchmarks were not available. Check with our team and learn how reporting some of our new QCDR measures can assist you in achieving a higher MIPS score.
- The quality data completeness requirement is still 70%, however CMS hinted that it will be most likely raised in the future. In addition, they did not remove the 3-point floor for scoring Quality measures, however this is likely to occur in 2023. This points to even more challenges in the future for providers trying to maximize their scores.
- The Cost performance category has become much more significant in the MIPS program, rising to 30% of the MIPS score. Additionally, CMS has added measures which will broaden the reach of the Cost category across more specialties. Healthmonix will provide a webinar later this month to discuss the Cost component and how we can help you better understand and prepare for this scoring.
- CMS has delayed many changes and mandates while providers continue to recover from the pandemic. However, they are interested in keeping momentum up for further evolving the program, so we see discussions about health equity focus, furthering interoperability and moving towards digital quality measures in the future.
- CMS is focused on moving towards MVPs in 2023. This has been a definite push by CMS even with the concerns that there are details to be worked through. There are many foundational components that have been laid out by CMS, and we will need to stay alert to prepare for 2023.
Every category of the Traditional MIPS program has been updated, requiring participants to stay alert regarding the program in order to avoid a penalty and maximize revenue.
Also note that the MIPS Value Pathways (MVPs) will launch in CY 2023. Healthmonix recently presented a webinar on MVPs that explained the reporting requirements and objectives for future participants. Subscribe to our blog and receive continual updates on Traditional MIPS, MVPs and other quality reporting programs in the QPP.
