The Centers for Medicare and Medicaid Services (CMS) issued the Final Rule for the 2022 Medicare Physician Fee Schedule (PFS) on November 2, 2021. The Rule makes several changes to the Quality Payment Program (QPP), including revisions to the existing MIPS program and a timeframe for transitioning to the new MIPS Value Pathway (MVPs). The MIPS Blog highlights some of the key takeaways for the substantial policy changes to traditional MIPS reporting in 2022 and future years that CMS has adopted.

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  • MIPS Eligible Clinicians – Two new clinician types have been added to the existing list: clinical social workers and certified nurse-midwives.
  • MIPS Performance Category Weight Changes – Beginning with the 2022 performance period, the Quality and Cost performance categories must be equally weighted at 30%. The weights for Promoting Interoperability and Improvement Activities remain the same as 2021 at 25% and 15%, respectively.
  • Minimum Performance Threshold and Payment Adjustments – For a prior performance period, beginning with the 2022 performance year, CMS is required to establish a performance threshold that is either the mean or median of the final MIPS scores for all MIPS eligible clinicians.
    • A minimum performance threshold of 75 MIPS points has been established for 2022.
    • An additional performance threshold of 89 points is established for exceptional performance, with 2022 being the last year for this additional MIPS adjustment.
    • Maximum payment adjustments for 2022 remain the same at plus or minus 9% and will be applied towards a clinician’s 2024 Medicare Part B payments for covered professional services, while a MIPS-eligible clinician who does not participate in MIPS in 2022 will receive a negative payment adjustment of -9% in 2024.
  • Quality Category – CMS has finalized changes in this category to the following 6 items: Data Completeness, Quality Measure Scoring, Bonus Points, Scoring for Groups Reporting Claims Measures, CMS Web Interface, and Quality Measures.
  • Cost Category – The Final Rule adds 5 newly-developed episode-based cost measures for the 2022 performance period.
  • Improvement Activities Category – There are updates to the Improvement Activities inventory for the 2022 performance year, including adding 7 new activities and modifying 15 current activities.
  • Promoting Interoperability Category – Beginning with the 2022 performance period, CMS will apply automatic reweighting to both clinical social workers and small practices.
  • Complex Patient Bonus – The complex patient bonus for the 2021 MIPS performance year will continue doubling.
  • Facility-Based Measurement – Unless a clinician or group receives a higher MIPS final score through another MIPS submission, the MIPS Quality and Cost performance category scores will be based on the facility-based measurement scoring methodology.
  • Redistributing Performance Category Weights for Small Practices – When the Promoting Interoperability performance category is reweighted, Quality will be weighted at 40%, Cost will be weighted at 30%, Improvement Activities will be weighted at 30%, and, in cases where both the Cost and the Promoting Interoperability performance categories are reweighted, the Quality and Improvement Activities categories will be equally weighted at 50%.

According to the California Medical Association, if a physician or small practice has submitted quality data codes on their 2021 Medicare claims, they will need to still file a 2021 MIPS Hardship Extreme and Uncontrollable Circumstances (EUC) exception to avoid a 2023 payment adjustment and be exempt from the 2021 MIPS program. Further, if a group practice that typically participates in MIPS as a group has not submitted 2021 data, then the automatic EUC policy will apply to the individual physicians within the group. If the group has submitted any 2021 data, then they will need to apply for the EUC to avoid a 2023 payment adjustment. This means that if the physician or practice has not submitted any 2021 MIPS performance data, then the automatic EUC will apply to the physician.