CMS Releases the 2022 QPP Proposed Rule – Here’s What You Need to Know

CMS Releases the 2022 QPP Proposed Rule – Here’s What You Need to Know

On July 13, 2021, CMS released its Quality Payment Program’s 2022 Proposed Rule, and while it is increasingly clear that CMS intends to move forward with their plan to eventually replace traditional MIPS with MIPS Value Pathways (MVP), there are changes to existing MIPS measures to be aware of. Comments are being accepted on the proposed rule through Sept. 13, 2021.

Overall, there are a number of changes to MIPS quality measures and MIPS healthcare standards that practices will need to be aware of. Here is a brief rundown of some of them that those looking at MIPS ophthalmology best practices should be aware of:

MIPS Eligible Clinician Types: An expansion of what would be considered an eligible clinician under MIPS has been proposed by CMS. It would include certified nurse mid-wives and clinical social workers. Under the MIPS’ Promoting Interoperability category, clinical social workers would reweight to zero.

MIPS Performance Thresholds: Starting with the 2022 performance year, MIPS will follow statute that requires that that performance be either the mean or median of the final scores for all MIPS eligible clinicians for a prior period. This means that:

  • The performance threshold is 75 points.
  • Additional performance thresholds are 89 points for exceptional performance.

The 2022 performance year will be the last for an additional performance adjustment for exceptional performance. By 2023, only penalty dollars will be used to fund the program. It seems likely that more providers will see negative payment adjustments as program changes make it more difficult to fall on the right side of the performance threshold.

Key Takeaways:

  • Performance category weights for Quality and Cost will finally equalize at 30 percent each.  Remaining the same from the 2021 performance year level are categories for Improvement Activities and Promoting Interoperability.
  • CMS wants to extend the web interface in traditional MIPS for registered groups, virtual groups, and APM entities with 25 or more clinicians.
  • Electronic Clinical Quality Measures (eCQMs), Medicare Part B Claims Measures, MIPS Clinical Quality Measures (MIPS CQMs), and QCDR Measures all remain available for traditional MIPS Quality category reporting.
  • Performance category weights for Quality and Cost will finally equalize at 30 percent each.  Remaining the same from the 2021 performance year level are categories for Improvement Activities and Promoting Interoperability.
  • CMS wants to extend the web interface in traditional MIPS for registered groups, virtual groups, and APM entities with 25 or more clinicians.

Electronic Clinical Quality Measures (eCQMs), Medicare Part B Claims Measures, MIPS Clinical Quality Measures (MIPS CQMs), and QCDR Measures all remain available for traditional MIPS Quality category reporting.

Quality Measures Get Updates

Look for 195 quality measures for the 2022 PY.  You can expect :

  • Substantive changes to 84 existing MIPS quality measures.
  • Changes to specialty sets.
  • Removal of measures from specific specialty sets.
  • 19 quality measures removed and 5 added, including 2 new administrative claims. Risk-Standardized Acute Unplanned Cardiovascular-Related Admission Rates for Patients with Heart Failure for MIPS is proposed, as is the Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions.

Meanwhile, benchmarking impacts due to COVID-19 will continue, and the agency wants to maintain the current data completeness threshold at 70%, though it could rise to 80% by 2023.

Quality Measure Scoring

There are plenty of new proposals here, including:

  • New measures: During the first 2 performance periods for a new measure, CMS proposes to create a 5-point floor scoring model.
  • Measures with and without a benchmark, and for those that don’t meet the minimum: The 3-point floors will be removed.
  • The ability to earn bonus points for both high-priority measure end-to-end electronic reporting will be removed.

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