The final rule for the 2022 MIPS program was released yesterday, and it contains major changes to how MIPS will be scored next year. Providers who have been avoiding the payment cut by simply submitting whatever data their EHR happens to capture may find this is no longer sufficient, and providers who have been earning 100% scores and the maximum upward payment adjustment every year may find this is no longer attainable. Providers without an EHR can still avoid the cut and even earn an upward adjustment, but this becomes even more difficult in 2022. However, some additional policies have been added that will make it easier for small practices who just want to avoid the payment cut to do so.

Currently available as a 2,414-page pre-publication PDF, the rule takes significant steps away from the “transition” policies enacted to help providers adapt to the MIPS program when it started and toward a version of the program where more providers receive meaningful payment adjustments (both upward and downward).

Some sources claimed that in later years of MIPS, half of providers would receive a payment cut, but thankfully, the math being applied by CMS means that isn’t likely to happen. Without getting into the details* of mean vs. median and historical vs. current period scores, the good news is that it’s mathematically possible for every provider to avoid the payment cut if they take the necessary steps during the reporting period.

Now, on to the biggest scoring changes for traditional MIPS, and what they mean:

  • The performance threshold will be 75 points out of 100: this is the score an eligible practice or provider must attain to avoid a payment cut. This is an increase from 60 points in 2021.
  • The exceptional performance threshold is 89 points: 2022 is the last year for the exceptional performance bonus with its additional pool of incentive money. In 2023 and beyond, all dollars to fund upward payment adjustments will come from payment cuts to other providers.
  • High-priority and end-to-end reporting bonuses in the quality category have been removed: this change will dramatically affect scoring for many providers. Many EHR and registry reporters could previously earn up to 12 bonus points in the quality category, or 20% of the total category score, just based on selecting enough of the right kinds of measures to submit. Without these bonus points, a 100% quality category score will be a lot harder to reach, and topped-out measures (those with a 7-point maximum score) become more of a problem.
  • The small practice quality bonus remains: clinicians in small practices will still have 6 points added to their quality score if any quality data is submitted.
  • Category weights have been changed: the quality and cost categories are now equally weighted at 30% (a decrease for quality and an increase for cost).
  • Small practices will have different policies from large practices for performance category reweighting when some categories are not reported or not applicable. This will be a benefit to providers in small practices who just want to avoid the payment cut, especially those who cannot report their quality measures through an EHR.
  • New cost measures were added: there are 5 new cost measures, including ones related to melanoma resection, asthma/COPD chronic disease care, and diabetes chronic disease care. This could cause some outpatient specialists who were previously excluded from the cost category to be scored on cost in 2022.
  • The complex patient bonus calculation was adjusted to prioritize “clinicians who have a higher share of socially and/or medically complex patients.” The maximum bonus will remain at 10 points as it has been for 2020 and 2021 (increased from 5 points due to COVID), but the changes to the calculation mean fewer clinicians may be eligible for these bonus points.

All MIPS-eligible providers should take the time now to ensure they have a plan in place to meet their goals for 2022 MIPS. What worked in 2020 and 2021 may not produce the same results in 2022, so it will be important to re-evaluate MIPS plans with plenty of time to make changes if needed.

Reach out to us with any questions you have about MIPS, or if we can help you create a plan to meet your goals in 2021 or 2022.

*For those who like the details: in order for claims that half of providers would receive a payment cut to be true, CMS would need to apply the payment adjustments based on scores from the performance period, with the performance threshold set at the median for the performance year (half of providers would therefore be above this threshold, and half would be below it). However, statute states that the performance threshold must be either the mean or the median of all providers from a prior period. In this case, they selected the mean from the 2017 performance year/2019 payment year.