Posted On: August 25, 2021
On July 13, 2021, CMS released the Quality Payment Program’s 2022 Proposed Rule. Based on the contents, is clear that CMS intends to move forward with their plan to eventually replace traditional MIPS with MIPS Value Pathways (MVP) but in the meantime, a variety of changes are directed to all aspects of the current program. The Proposed Rule is open for comment by stakeholders (that means you) until September 13, 2021. This article highlights the important proposed changes that will impact future reporting.
MIPS Eligible Clinician Types
CMS proposes to expand the definition of a MIPS eligible clinicians to include:
This change is proposed to align to the APM eligible clinician definition. CMS anticipates that both clinician types will have an appropriate level of quality measures and Improvement Activities.
CMS also proposes that Clinical Social Workers may automatically reweight to zero for the Promoting Interoperability category of MIPS.
No clinician types have been proposed for removal from the eligible clinician definition.
MIPS Performance Thresholds
CMS will follow statute beginning with the 2022 performance year. Statute requires that that the performance threshold must be either the mean or median of the final scores for all MIPS eligible clinicians for a prior period.
Therefore, CMS proposes the use of the mean final score from the 2017 performance year/2019 payment year to set the 2022 performance threshold. This results in the following:
Also required by statute, the performance category weights for Quality and Cost will finally equalize at 30 percent each. Improvement Activities and Promoting Interoperability categories remain unchanged from 2021 performance year levels :
For Traditional MIPS APM Entities, the scoring will be unchanged from the 2021 PY.
For APP: Individuals, Groups and APM Entities, the scoring will be unchanged from the 2021 PY.
Traditional MIPS: APM Entities (no change)
APP: Individuals, Groups, APM Entities (no change)
Performance Category Specific Proposals
Quality Performance Category
The following changes are proposed for the 2022 Quality performance category:
CMS proposes to extend the CMS Web Interface in traditional MIPS for registered groups, virtual groups and APM Entities with 25 or more clinicians.
The following collection types remain available for traditional MIPS Quality category reporting for the 2022 PY:
CMS proposes changes to the Quality Measure inventory. The proposed inventory will have a total of 195 quality measures for the 2022 PY. These changes include:
The 2 proposed administrative claims measures are:
(See Appendix A / Table A for measure change details)
Extreme and Uncontrollable circumstances policies in effect due to COVID-19 will impact benchmarking sources in 2022. CMS proposes to use performance period benchmarks or benchmark data from another performance period, such as CY 2019, to establish benchmarks.
CMS proposes to maintain the current data completeness threshold at 70% for the 2022 performance year
Quality Measure Scoring
Currently, there is no policy in place to address new measure scoring other than to award 3 points for measures without a benchmark. In preparation to align Quality Measure Scoring with MVPs, and to move away from scoring methodology used during the transitional phase of MIPS, CMS proposes the following:
For New Measures – During the first 2 performance periods for a new measure, CMS proposes to create a 5-point floor scoring model. This would work as follows:
Measures with a benchmark – CMS proposes to remove the 3-point floor for measures that can be scored against a benchmark
Measures without a benchmark – Currently 3 points are awarded to these measures. CMS proposes to remove the 3-point floor for measures that do not have a benchmark for PY 2022.
Measures that do not meet case minimum (20 cases) – Currently 3 points are awarded to these measures. CMS proposes to remove the 3-point floor.
CMS proposes to remove the ability to earn bonus points for both High-Priority measure reporting and End-to-End Electronic Reporting.
Quality Scoring Flexibilities
CMS proposes to expand the list of reasons that a quality measures may be impacted to include errors that cause to suppress or truncate a measure. These errors include, but are not limited to:
Scoring for Groups reporting Part B claims measures
CMS proposes to only calculate a group-level quality performance category score from Medicare Part B Claims measures if the practice submitted data for another performance category as a group (signaling their intent to participate as a group). This will differ from the previous method to automatically calculate at individual and group levels for small practices.
Cost Performance Category
CMS proposes to add 5 new episodic-based cost measures:
2020 Category Reweighting
Due to Covid-19, CMS determines that they cannot reliably calculate scores for the Cost measures, therefore, a weight of zero will be assigned to the cost performance category for the 2020 performance year/2022 payment year.
Improvement Activities Performance Category
Along with proposals directed towards processes guiding addition of new and removal of existing activities due to obsolescence or patient safety concerns, CMS is proposing the addition of 7 new improvement activities and modification to 15 current activities and removal of 6 activities.
See Appendix A / Table B for the IA list
Promoting Interoperability Performance Category
The proposed rule deals out its fair share of changes in the PI category of MIPS. For 2022, CMS proposes the following:
Reweighting – to automatically apply reweighting to two clinician types
Revision of Reporting Requirements
Revision of Measure – Provide Patients Electronic Access to the Health Information
Public Reporting – Care Compare
CMS Proposes to add affiliations for the following facility types on Care Compare:
Complex Patient Bonus
CMS also proposes to revise the complex patient bonus beginning with the 2022 MIPS performance year/2024 MIPS payment year by:
Medicare Shared Savings Program
For performance year 2022, ACOs would either report the 10 CMS Web Interface measures or the 3 eCQMs/MIPS CQMs. Under the APP, all ACOs would administer the CAHPS for MIPS Survey and be scored on 2 administrative claims-based measures (calculated by CMS).
For performance year 2023, ACOs would either report the 10 CMS Web Interface measures and at least one eCQM/MIPS CQM or the 3 eCQMs/MIPS CQMs. Under the APP, all ACOs would continue to administer the CAHPS for MIPS Survey and be scored on 2 administrative claims-based measures (calculated by CMS).
In order to transition ACOs to reporting all-payer eCQM/MIPS CQM measures, CMS would only score the CMS Web Interface measure set for an ACO that has also submitted at least one eCQM/MIPS CQM measure.
Coupled with CMS’ proposed revisions to the quality reporting requirements for the Shared Savings Program, they are proposing to freeze the quality performance standard at the 30th percentile MIPS quality performance category score for PY 2023, as well as providing an incentive for ACOs to report eCQM/MIPS CQM measures in performance years 2022 and 2023.
For performance year 2022, if an ACO reports:
For performance year 2023, if an ACO reports:
In performance year 2024, the threshold for the quality performance standard will increase to the 40th percentile MIPS Quality performance category score.
Finally, for performance year 2021 and subsequent performance years, CMS confirms that the CAHPS for MIPS minimum sampling thresholds also apply to Shared Savings Program ACOs.
APM Performance Pathway (APP) Proposal
CMS proposes to allow MIPS eligible clinicians to report the APP as a subgroup beginning with the 2023 performance year. The definition of a subgroup and eligibility to participate as a subgroup are the same for MVP and APP reporting.
MIPS Value Pathways (MVP)
The 2022 QPP Proposed Rule includes information related to the introduction of MIPS Value Pathways (MVPs). This highly anticipated topic will be covered in an upcoming blog post, coming soon!
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