It’s a new year, and that means a new set of policies for the traditional Merit-Based Incentive Payment System (MIPS) program. As a reminder, the traditional MIPS program comprises the cost, quality, improvement activities (IA), and Promoting Interoperability (PI) performance categories. Your performance in these categories will result in your MIPS final score (0 – 100 points). Your MIPS final score for the 2022 performance year will determine whether you receive a negative, neutral, or positive MIPS payment adjustment for covered professional services in 2024. If you haven’t done so already, check your MIPS participation status for 2022.
Although many of the reporting requirements remain the same as last year, CMS has made some key changes for 2022, including:
- MIPS cost measures will play a greater role in the 2022 performance year. For individuals, groups and virtual groups, CMS will weigh the performance category as follows:
- 30% for the quality performance category (a 10% decrease from performance year 2021).
- 30% for the cost performance category (a 10% increase from performance year 2021).
- 15% for the IA performance category (same as performance year 2021).
- 25% for the PI performance category (same as performance year 2021).
- Allergists/immunologists will now need 75 MIPS points to avoid a penalty.
- The exceptional performance bonus threshold was increased from 85 points to 89 points. The 2022 performance year is the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.
- CMS removed the high priority and end-to-end electronic reporting measure bonus points.
- One quality measure—Medication Management for People with Asthma—was removed from the A/I specialty measure set.
- There are five new episode-based cost measures for 2022, including the Asthma/Chronic Obstructive Pulmonary Disease chronic condition measure.
- CMS will automatically reweight the PI performance category for MIPS eligible clinicians in small practices (15 or fewer clinicians). CMS will no longer require an application for clinicians and small practices seeking to qualify for the small practice hardship exception and reweighting. However, if a small practice submits data for the PI performance category, the data will be scored and the PI performance category will not be reweighted.
The following chart provides a high-level overview of changes to certain MIPS policies in the 2022 Quality Payment Program (QPP) final rule.
MIPS Policies 2021 vs. 2022
|Policy||CY 2021 Policies||CY 2022 Policies|
|COVID-19 Extreme and Uncontrollable Circumstances Exception||Allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.||No change|
|Category Weights for Traditional MIPS: Individuals, Groups, and Virtual Groups||Quality 40%
|Redistributing Performance Category Weights for Small Practices (15 or Fewer Eligible Clinicians)||Reweighted under the same redistribution policies as other MIPS eligible clinicians.||CMS will automatically reweight the PI performance category for MIPS eligible clinicians in small practices (15 or fewer clinicians). However, if a small practice submits data for the PI performance category, the data will be scored and the PI performance category will not be reweighted.
When the PI is reweighted:
|Part B Claim Measures||No longer automatically scoring Part B claims measures reported by small practices, at the individual and group level
CMS will only calculate a group-level quality score from Part B claims measures as a group if the practice submits group-level data in another performance category.
|Low Volume Threshold||Bill >$90,000 Medicare Part B charges
See >200 Part B patients AND
Provide >200 covered services to Part B patients
|CEHRT Edition||Clinicians may use technology meeting the 2015 Edition certification criteria, technology certified to the 2015 Edition Cures Update certification criteria, or a combination of the two to report data for the PI performance category, and to report electronic clinical quality measures (eCQMs) for the quality performance category.||No change|
|Small Practice Bonus
(15 or Fewer Eligible Clinicians)
|Six bonus points added to quality for the submission of at least one quality measure||No change|
|Complex Patient Bonus||Continue to double the complex patient bonus, capped at ten points||• Limit the bonus to clinicians who have a median or higher value for at least one of the two risk indicators (Hierarchical Condition Category score and proportion of patients dually eligible for Medicare and Medicaid benefits).
• Update the formula to standardize the distribution of two risk indicators so the policy can target clinicians who have a higher share of socially and/or medically complex patients.
• Increase the bonus to a maximum of ten points.This bonus will be available to those that meet the criteria above and submit data for at least one performance category.
|Outcome and High-Priority Bonus Points||Each additional outcome or patient experience measure, beyond the one required outcome measure, receives two bonus points if certain criteria are met.
Each additional high-priority measure, beyond the one required outcome measure, receives one bonus point if certain criteria are met.
|There are no bonus points for reporting additional outcome and high priority measures, beyond the one required.|
|End-to-End Electronic Reporting Bonus Points||Each measure that meets end-to-end electronic reporting criteria receives one bonus point.
Measures do not have to meet data completeness or case minimum.
|There are no bonus points for measures that meet end-to-end electronic reporting criteria.|
|Quality Data Submission Options||For groups, virtual groups and APM entities reporting traditional MIPS for the 2022 Performance Period:
|For groups, virtual groups and APM entities reporting traditional MIPS for the 2022 Performance Period:
|Quality Measures||209 quality measures available for the 2021 performance period||200 quality measures available for the 2022 performance period
Removal of one quality measure from the A/I specialty measure set, bringing the new total to 13 measures
|Cost Category||Added 5 newly developed episode-based cost Measures, including the Asthma/Chronic Obstructive Pulmonary Disease (COPD) chronic condition measure|
|Quality Data Completeness Threshold||70% of patients who qualify for each measure||No change|
|Performance Threshold: Minimum Points to Avoid a Penalty||60 points||75 points|
|Exceptional Performance Threshold||85 points||89 points
2022 performance year is the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.
|MIPS Value Pathways (MVP)||MVP reporting will be optional in performance year 2023.|
For additional information, please refer to the QPP Resource Library, which includes:
- 2022 MIPS Overview Quick Start Guide – Provides a high-level overview of MIPS requirements to get you started with participating in the 2022 performance year.
- 2022 MIPS Quick Start Guide for Small Practices – Provides a high-level overview of MIPS requirements for small practices to get you started with participating in the 2022 performance year.
- 2022 MIPS Eligibility and Participation Quick Start Guide – Provides high-level information and actionable steps for interpreting your eligibility and participation requirements for the 2022 MIPS performance period.
- 2022 MIPS Quality Performance Category Quick Start Guide – Provides the high-level requirements and practical information about quality measure selection, data collection, and submission for the 2022 performance period for individual, group, and virtual group participation.
- 2022 MIPS Promoting Interoperability Performance Category Quick Start Guide – Provides a high-level overview and practical information about data collection and submission for the 2022 MIPS PI performance category.
- 2022 MIPS Improvement Activities Quick Start Guide – Provides a high-level overview and practical information about data collection and submission for the 2022 MIPS IA performance category.
- 2022 MIPS Cost Performance Category Quick Start Guide – Provides a high-level overview of cost measures, including calculation and attribution, for the 2022 MIPS cost performance category.
- 2022 QPP Final Rule Resources – A zip file containing 2022 QPP final rule resources, including the 2022 QPP Final Rule fact sheet, FAQs, and comparison tables.
- 2022 QPP Final Rule – Rule updating the QPP.
Available measures and activities for each performance category under traditional MIPS can be accessed here:
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS