Finalized proposals in the CY 2022 Physician Fee Schedule for the Quality Payment Program (QPP) indicate that the Centers for Medicare & Medicaid Services (CMS) is moving ahead to evolve the Merit-based Incentive Payment System (MIPS) program. Specifically, changes will come to the current requirements and the timeline for implementation of MIPS Value Pathways (MVPs).
Statutory requirements necessitate modifying the performance threshold to the mean or median of the final scores for all MIPS-eligible clinicians for a prior period, adjustments to threshold scoring, and reweighting performance categories. Other changes include new episode-based cost measures, changes in the Improvement Activities category, and revised objectives in the Promoting Interoperability category.
There are significant updates to quality measures as well. MVPs are intended to be more relevant to clinician specialty, patient condition, and outcomes. They will also simplify reporting for clinicians through alignment of measures across all four performance categories.
CMS planned the transition to MVPs in 2020, but delayed implementation given stakeholder feedback and the COVID-19 public health emergency (PHE). Implementation now begins with voluntary reporting in 2023 and mandatory reporting in 2028.
The MVPs available in 2023 include:
- Advancing rheumatology patient care
- Coordinating stroke care to promote prevention and cultivate positive outcomes
- Advancing care for heart disease
- Optimizing chronic disease management
- Adopting best practices and promoting patient safety within emergency medicine
- Improving care for lower extremity joint repair
- Support of positive experiences with anesthesia
Program and measure changes for 2022
CMS finalized a minimum performance threshold of 75 MIPS points for 2022 – the mean of final scores from 2017 – which is an increase from 60 MIPS points in 2021. Clinicians must achieve a MIPS score of 75 points to avoid a penalty and 89 points for an exceptional performance bonus.
Additionally, the Quality and Cost categories are now equally weighted at 30%. Both Promoting Interoperability and Improvement Activities remain the same, at 25% and 15% respectively.
Measure changes maintain alignment with the traditional MIPS framework while continuing to advance the program until MVPs are available.
The five new cost measures include:
- Two procedural measures: Melanoma resection, colon and rectal resection
- One acute inpatient measure: Sepsis
- Two chronic condition measures: Diabetes, asthma/chronic obstructive pulmonary disease [COPD]
Improvement Activities now reflect a greater emphasis on health equity, modifying 15 activities and introducing seven new activities in the following subcategories:
- Achieving health equity
- Behavioral and mental health
- Emergency response and preparedness
- Patient safety and practice assessment
Six Improvement Activities were deemed low value or duplicative and removed.
Measures in the Quality category underwent the most significant change. Four new measures focus on chronic conditions and patient reported outcomes. Fifteen duplicative or topped out measures were removed. Eighty-seven measures were updated to better align with clinical specialty, and one new measure set was added for certified nurse-midwives.
The 2022 final rule is a clear indication that CMS is enacting a major overhaul to MIPS, with changes to current program requirements and a thoughtful plan for the incremental transition to MVPs. Eligible clinicians should begin reviewing these changes to understand the potential impact on their reporting practices for 2022 and consider updates to workflows and systems needed to support MVPs.
