The Centers for Medicare and Medicaid Services (CMS) published the 2022 Medicare Physician Fee Schedule proposed rule recommending a number of changes to the Quality Payment Program (QPP), including the traditional Merit-based Incentive Payment System (MIPS) program. As a refresher, traditional MIPS comprises four performance categories: Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA). A provider’s score for each of these categories determines one’s total MIPS score and corresponding payment adjustment.
This is the first article in a multi-part series that provides a summary of CMS’s proposed changes to the QPP and how they may affect you. This article focuses on key performance categories’ weighting and final scoring proposals for the traditional MIPS program.
CMS has announced they will be updating the MIPS performance feedback and final scores for some clinicians for performance year 2020, along with the associated MIPS payment adjustment information for 2022. You may see a change to your current 2020 final scores and 2022 payment adjustment.
You can view your current MIPS performance feedback, final score, and payment adjustment on the Quality Payment Program website – but the information you see now may change. To learn more about the information in your performance feedback, review the following 2020 MIPS resources:
- 2020 Performance Period Benchmarks (ZIP) – Identifies the performance period benchmark results (as available) for measures without a historical benchmark and provides general information about performance period benchmarks.
- 2020 MIPS Performance Feedback FAQs (PDF) – Highlights what performance feedback is, who receives the feedback, and how to access it on the Quality Payment Program website.
- 2022 MIPS Payment Year Payment Adjustment User Guide (PDF) – Reviews information about the calculation and application of MIPS payment adjustments, and answers frequently asked questions.
Low-Volume Threshold
In good news for allergists, the proposed low-volume threshold for MIPS in 2022 remains the same: you are exempt if your annual Medicare Part B allowed charges are equal to or less than $90,000, or you furnish covered professional services to 200 or fewer Medicare Part B patients, or you provide 200 or fewer covered professional services to Part B patients.
Performance Category Weights
Beginning with the 2022 performance year (2024 payment year), CMS is required to weigh the Cost and Quality performance categories equally. 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).
This means MIPS cost measures will play a greater role. In a future article on QPP, we will address cost measures relevant to the allergy specialty.
Redistribution
General
Under certain circumstances, such as when there are insufficient measures and activities applicable and available, CMS will assign to a performance category a scoring weight different from the aforementioned weights and will redistribute the weight to another performance category(ies). For example, CMS may redistribute weight when, for the cost performance category, the agency cannot reliably calculate a score for the cost measures that adequately captures and reflects the performance of the clinician. CMS previously finalized the following policy for redistributing the performance category weights for the 2022 performance year (2024 payment year). CMS is proposing to maintain this redistribution policy for subsequent performance years:
| Reweighting One Performance Category | ||||
|---|---|---|---|---|
| Reweighting Scenario | Quality | Cost | IA | PI |
| No cost | 55% | 0% | 15% | 30% |
| No PI | 55% | 30% | 15% | 0% |
| No Quality | 0% | 30% | 15% | 55% |
| No IA | 45% | 30% | 0% | 25% |
| Reweighting Two Performance Categories | ||||
|---|---|---|---|---|
| Reweighting Scenario | Quality | Cost | IA | PI |
| No Cost/PI | 85% | 0% | 15% | 0% |
| No Cost/ Quality | 0% | 0% | 15% | 85% |
| No Cost/IA | 70% | 0% | 0% | 30% |
| No PI/Quality | 0% | 50% | 50% | 0% |
| No PI/IA | 70% | 30% | 0% | 0% |
| No Quality/IA | 0% | 30% | 0% | 70% |
Small Practices
To account for potential burden on small practices (15 or fewer eligible clinicians) –
which include many allergy practices – and reduce the disparity between large and small practices, CMS is proposing different redistribution weights for small practices beginning with the 2022 performance year (2024 payment year):
| Reweighting One Performance Category | ||||
|---|---|---|---|---|
| Reweighting Scenario | Quality | Cost | IA | PI |
| No PI | 40% | 30% | 30% | 0% |
| Reweighting Two Performance Categories | ||||
|---|---|---|---|---|
| Reweighting Scenario | Quality | Cost | IA | PI |
| No Cost/PI | 50% | 0% | 50% | 0% |
In all other reweighting scenarios, the aforementioned general redistribution policies apply.
Complex Patient Bonus
To address the impact patient complexity may have on MIPS scoring, CMS adds a complex patient bonus to the MIPS final scores. CMS is proposing changes to the complex patient bonus for the 2021 performance year (2023 payment year) and the 2022 performance year (2024 payment year). For the 2021 performance year, CMS proposes to continue doubling the maximum complex patient bonus to 10 points to reflect COVID-19 concerns. For the 2022 performance year, CMS proposes revised formulas for the complex patient bonus and an overall cap of 10 bonus points. For additional details, please refer to pages 39,439-46 of the proposed rule.
Performance Threshold
For the 2022 performance year (2024 payment year), CMS proposes to increase the performance threshold to 75 points and the additional performance threshold to 89 points for exceptional performance. Accordingly, under the proposal, clinicians and group practices must receive at least 75 points to avoid a negative payment adjustment for the 2024 payment year and must earn at least 89 points to receive an additional MIPS adjustment for exceptional performance.
The 2022 performance year (2024 payment year) is the last year that CMS will provide an additional MIPS payment adjustment for exceptional performance.
| Final Score 2021 | Final Score 2022 (Proposed) | Payment Adjustment |
|---|---|---|
| At least 85 points | At least 89 points | Positive adjustment greater than 0% and eligible for additional payment fo exceptional performance. |
| 60.01 – 84.99 points | 75.01 – 89.99 points | Positive adjustment greater than 0% |
| 60 points | 75 points | Neutral payment adjustment |
| 15.01 – 59.99 points | 18.76 – 74.99 points | Negative payment adjustment less than 9% but greater than -9% |
| 0 – 15 points | 0 – 18.75 points | Negative payment adjustment of -9% |
Read more on the 2022 QPP proposed rule.
Watch for the next Advocacy Insider as we discuss CMS’s proposals concerning the Quality, Cost, Improvement Activities, and Promoting Interoperability performance categories. The Advocacy Council – we have you covered.
