2022 MIPS Guide - Merit Based Incentive Payment System

MIPS Guide 2022

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established the Medicare Quality Payment Program (QPP) to reward good value and low-cost treatment. As per the 2022 MIPS guide, Eligible clinicians choose one of two payment tracks annually: 

1. Merit Based Incentive Payment System (MIPS) and
2. Advance alternate payment model (APM). 

What is MIPS?

MIPS (merit based incentive payment system) is the program that will determine Medicare payment adjustments. ECs (eligible clinicians) may receive a payment bonus, penalty, or no payment adjustment using a composite performance score.

MIPS keeps paying qualifying clinicians on a fee-for-service basis while also requiring them to report PI (Promoting Interoperability), IA (Improvement Activities), and quality data. MIPS consultant ensures the practice performance under the designated compliance of MIPS parameters. Clinicians are assessed on their performance compared to other clinicians across the states at the end of each performance year. Their Medicare Part B payments are adjusted positively, neutrally, or negatively each two years later. Payments in 2024, for example, will be influenced by performance in 2022. Payment adjustments for the fiscal year 2022 may vary from -9 to +9%. 

MIPS Participation Option

Clinicians can participate as either individuals or in groups. All ECs reporting within the TIN (tax identification number) must be included in the group’s reporting when reporting as a group. Each “NPI” (national provider identifier) within the TIN will receive a MIPS final score. A TIN cannot be split into several groups.

• An Individual can be defined as an NPI (single National Provider Identifier) tied to a single Tax Identification Number (TIN); OR
• At least two physicians (identified by their NPIs) who have a standard TIN are considered a group. At least one clinician must be individually eligible for MIPS.

Important: For a given performance year, the decision to report individually or as a group applies to all MIPS categories. In some categories, a clinician cannot opt to report as an individual while reporting as a group in others. Whether to report as a group or by individual clinicians has financial and reputational ramifications that must consider.

1. Quality (30%) 

• Physicians must provide six measures, one of which must be an outcome measure. The reporting period is one calendar year.
• For groups of 16 or more qualified physicians with a minimum of 200 eligible patients, the “CMS” (Centers for Medicare & Medicaid Services) will use claims data to establish the all-cause hospital readmission measure.
• A 7-point floor was established for new Quality measures for the first performance period, and a 5-point floor would be established for the second performance period in 2022.
• Physicians must report on 70% of patients who meet the criteria for each measure, regardless of payer. Only Medicare Part B patients include in reports submitted via the CMS Web Interface or claims.
• Bonus points are no longer available in 2022 for end-to-end (ETE) electronic reporting and reporting additional outcome/High-priority measures beyond the set parameters.

2. Promoting Interoperability (25%)

• Eligible clinicians must report on a set of required measures and performance based on scores.
• Failure to report any of the mandatory measures will ultimately result in a score of zero for the entire performance category.
• Adopts the Safety Assurance Factors for EHR Resilience Guides as a new mandatory measure (SAFER Guides). Beginning with the 2022 performance period, MIPS qualified doctors must attest to undertaking an annual evaluation of the SAFER Guides.
• The 2022 performance period alone adds the fourth exclusion to the Electronic Case Reporting: Before the commencement of the performance period, they choose in 2022 they use “CEHRT”(certified-electronic-health-record-technology)” that is not certified to the electronic case reporting certification standard.
• Improves the attestation statements for Information Blocking Prevention.

3. Cost (30%)

• Twenty-five cost measures have been designed for the MIPS performance period 2022.
• CMS determines costs using claims data.
• No, data submission is required.
• An Eligible clinician’s performance compares to a benchmark, and a score of one to 10 is assigned. The cost category score is the average of all cost measures that have been scored.
• CMS collaborates with measure development firm Acumen, LLC to produce episode-based cost measures. As part of the process of developing a measure, the following five measures will field test in January 2022: Heart Failure, 2. Low Back Pain, 3. Major Depressive Disorder, 4. Emergency Medicine, 5. Psychoses/Related Conditions.
• CMS is also beginning the process of prioritizing and conceptualizing four more episode-based cost measures. These will introduce between 2022 and 2023.

4. Improvement Activities (15%)

• For the 2022 performance year, CMS has developed a list of more than 100 activities. 
• Each improvement activity is assigned a high or medium weight. Those with a medium weight earn 10 points, while activities with a high weight receive 20 points. Eligible groups and clinicians must receive a score of 40 points to receive full credit for the performance category.
• Eligible clinicians/Physicians and groups are subject to auditing from their registry/data vendor or CMS for up to 6 years AFTER the performance year.
• For groups, CMS mandates that 50% of the group’s “NPI” (National Provider Identifier) clinicians conduct the same improvement activity within 90 days during the same performance year.
• ECs in small practices (15 or fewer clinicians), rural practices, or “HPSA” can report one high weighted activity or two medium-weighted activities (measures are double weighted).
• Eligible clinicians and their affiliated groups should retain documentation of their improvement activity performance.

MIPS reporting requirements are the same for all specializations. That’s why NEO MD CMS Certified Registry of MIPS consultants work with a variety of practices to help them provide—and report on—the best quality of care measures, regardless of their EHR and PM platforms.YOU CAN REACH US for MIPS consulting services at (registry@neomdinc.com) or (929) 502-3636.