MIPS PY 2022; The Hardest Year Yet

Traditional MIPS has addressed all eligible clinicians with some preset performance enhancement goals. However, we have clarity today that this program is soon going to be overtaken by another reporting framework. Do you know about this framework? Yes, it is not other than the MIPS Value Pathways (MVPs). MVPs do not appear in the QPP program all of a sudden. Rather, QPP has slowly turned the participants towards this new pathway. And for this purpose, it has aligned several modifications in the MIPS program. Though, eligible clinicians have completed the MIPS 2022 performance year. Anyhow, we must say here that it was never that easy for providers to complete the MIPS reporting. They have molded their MIPS-related strategies to give a fine performance in MIPS 2022.

Highlights of MIPS 2022 Performance Year

● MIPS 2022 has a strict data completeness requirement for all as we have moved away from the COVID-19 obstacles. Now, all the providers have overcome the drastic conditions and they are in the perfect form of performing.

● After the MIPS performance year 2022, clinicians will not get any sort of exceptional performance bonuses. So, PY 2022 will be the last year of scoring such a bonus on getting the 89 points in MIPS score.

● The potential payment adjustment criteria are the highest in MIPS 2022. A practice can either get the +9 percent incentives on hitting the performance threshold or an equal -9 percent penalty in opposite cases.

● Additionally, the performance threshold has been raised from 60 points. This is 75 points for MIPS 2022 reporting.

● In MIPS 2021, CMS has provided reweighting options to clinicians whose practices were adversely affected by COVID-19. Anyhow, these relaxations have been suspended from the MIPS 2022 PFS final rule document. Only those with some severe conditions can apply for the category reweighting application in certain conditions.

Let’s see how the new modifications in the Traditional MIPS program have influenced the practices in PY 2022.

MIPS Program’s Difficulty Level Upgraded for Penalty Avoidance

We have three underlying reasons that encourage the toughest conditions for providers in giving a miss to penalty. The most considerable factor is the CMS’ consideration of the Cost category. In MIPS 2021, the Cost category has contributed little weight than the quality. However, CMS has given 30% weightage to each of these categories for this year. According to the criteria of the MACRA Act, the Cost category determination will be done by CMS using claims data. Clinicians are “flying blind” in the Cost category since CMS doesn’t offer any performance feedback on those measurements during the performance year.

Moreover, CMS is recommending that the End-to-End Electronic Submission and High Priority measure bonus points in the Quality category be dropped. In addition, it has better reflected the difficulties experienced by physicians working with high-risk (HCC) and dual-eligible patient groups. So, the number of clinicians who will earn a Complex Patient Bonus will be lowered in half.

Sunsetting of Web Interface Submissions

CMS Web Interface is the go-to-on MIPS data collection type in traditional MIPS for many years. Anyhow, CMS has closed this submission option for traditional MIPS participants in MIPS 2022 and so on. However, Medicare Shared Savings Programs ACOs can use it for some time. Instead of directly submitting MIPS data on the Web interface, clinicians are provided with eCQMs or CQMs. This implies that either they have to get the ONC-certified EHR systems or get MIPS consultancy from any qualified registry. This new CMS rule will impose on Medicare ACOs as well. NAACOs have very serious concerns about the implementation of this infrastructure.

Favorable Transitioning to MVPs; Delayed Until MIPS 2023

It has been clarified that clinician reporting in Traditional MIPS has to end in the coming years. However, CMS has informed them about a third reporting framework; the MVPs. Though, CMS has made certain changes to prepare the providers for MVP reporting before launching them. Yet, in MIPS 2022, MIPS participants got hope of MVPs reporting commencement in PY 2023. Anyhow, participation in MVPs will not be mandatory for clinicians till MIPS 2023 and MIPS 2024. CMS has launched the 7 available MVPs for MIPS participants to arrange their strategies accordingly. However, shifting to MVPs while still participating in MIPS 2022 was a huge task to do. The clinicians have somehow managed and performed in the best possible way.

Endnote

MIPS 2022 not only came with new reporting challenges, but it has also pointed to the upcoming difficulties for the providers. Those who have shown attentiveness to all these summonses have secured their position in MIPS performance year 2022 and for the future years as well. Here, we suggest all providers come to us for our MIPS consulting services. We can better arrange their activities and help them in accepting the proposed changes in the MIPS program.