On November 2, 2021, CMS published the Physician Fee Schedule Final Rule for 2022. We have developed a summary of the highlights pertaining to the Quality Payment Program (QPP). We are unable to cover every detail in this summary; reach back to our QPP experts to address specific questions at info@velerohealth.com to request a convenient appointment.
Key Takeaway: CMS will launch the MIPS Value Pathways (MVPs) in 2023.
In CY 2021, CMS delayed implementation of the MVPs until the 2022 performance period or later. We now know the MVPs will launch in 2023. The MVPs are a voluntary participation option to motivate clinicians to move away from reporting on self-selected activities and measures (Traditional MIPS) and towards an aligned set of measure options designed to be meaningful to patient care and more relevant to a clinician’s scope of practice. In this rule, the agency set an implementation timeline, defined MVP criteria, and finalized the first set of MVPs for performance year 2023.
- MVP Implementation Timeline: begins in CY 2023
- MVP Criteria:
- at least one outcome measure, or
- one high-priority measure relevant to each specialty participating in the MVP in instances when an outcome measure is not available.
- Qualified Clinical Data Registry measures must be fully tested
- MVP Participation Options:
- 2023-2025) Individual clinicians, single specialty groups, multispecialty groups, subgroups and APM entities can report MVPs
- (2026) Multispecialty groups will be required to form subgroups to report MVPs
- 2023 MVPs: seven MVPs
- Rheumatology, Stroke Care and Prevention, Heart Disease, Chronic Disease Management, Emergency Medicine, Lower Extremity Joint Repair and Anesthesia
Key Takeaway: CMS increased the threshold to avoid MIPS negative payment adjustments.
The MIPS performance threshold for the 2022 performance year is 75 points. To avoid a penalty in the 2024 payment year, providers’ MIPS Total Score must reach this performance threshold in 2022. CMS is required by statute to base the MIPS performance threshold on the mean or median of a previous year. While the increase is in line with increases from previous years, this is the first time that CMS has based the performance threshold on a previous year’s score. The top tier performance threshold is set at 89 points for an exceptional performance adjustment. Performance year 2022 is the final year for the exceptional performance adjustment.
Key Takeaway: Changes to MIPS 2022 Performance Categories and Weights
- Quality
- Reduction from 209 measures to 200 (removal of 13 and addition of four), plus modifications to 87 existing measures and changes to specialty sets
- Cost
- Addition of five episode-based cost measures
- Improvement Activities
- Addition of seven new improvement activities, removal of six and modification of 15
- Promoting Interoperability
- Revisions to reporting requirements, including addition of new measures.
The 2022 MIPS performance category weights, which are specified in statute, are summarized below.
Note* that those participating in Traditional MIPS as an APM entity or in the APM Performance Pathway as an individual, group or APM entity will have different scoring weights than those described above.
Key Takeaway: MIPS Participation Expanded
- For 2022, MIPS eligible clinician definition expanded to include:
- clinical social workers
- certified nurse midwives
Key Takeaway: Complex Patient Bonus Extended
CMS will double the complex patient bonus (capped at 10 points) through 2022. The bonus was implemented in 2021 (due to the pandemic) and is applied to the MIPS Total Score.
Key Takeaway: Quality Measures Removed for 2022 Performance Year
- 14: Age-Related Macular Degeneration (AMD): Dilated Macular Examination
- 21: Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second-Generation Cephalosporin
- 23: Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients)
- 44: Coronary Artery Bypass Graft (CABG): Preoperative Beta-Blocker in Patients with Isolated CABG Surgery
- 50: Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older
- 67: Hematology: Myelodysplastic Syndrome (MDS) and Acute Leukemias: Baseline Cytogenetic Testing Performed on Bone Marrow
- 70: Hematology: Chronic Lymphocytic Leukemia (CLL): Baseline Flow Cytometry
- 154: Falls: Risk Assessment
- 195: Radiology: Stenosis Measurement in Carotid Imaging Reports
- 225: Radiology: Reminder System for Screening Mammograms
- 337: Psoriasis: Tuberculosis (TB) Prevention for Patients with Psoriasis, Psoriatic Arthritis and Rheumatoid Arthritis on a Biological Immune Response Modifier
- 342: C.16. Pain Brought Under Control Within 48 Hours
- 429: Pelvic Organ Prolapse: Preoperative Screening for Uterine Malignancy
- 434: C.18. Proportion of Patients Sustaining a Ureter Injury at the Time of Pelvic Organ Prolapse Repair
- 444: Medication Management for People with Asthma
Medicare Shared Savings Programs (MSSP)
CMS freezes the quality performance standard at the 30th percentile and provides an incentive for ACOs to report eCQM/MIPS CQM in PY 2022 and 2023. In PY 2024, the threshold for quality performance standard would increase to the 40th percentile across all MIPS quality performance category scores.
Key Takeaway: The final rule codifies the CAA provision to freeze Advanced APM thresholds at 2020 levels.
Statute sets specific revenue and patient count thresholds that APMs are required to meet to qualify for their 5% advanced APM bonus payment. The thresholds were slated to dramatically increase in 2021 for the 2023 bonus payment, but the CAA of 2021 held the thresholds at the 2020 levels for two years. The final rule implements this statutory change. Under the new provision, the thresholds remain at 50% for the payment method and 35% for the patient count method for 2023 and 2024 payment years (2021 and 2022 performance years). Absent congressional action, the 2022 performance year is the last year of the advanced APM bonus.
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