On Nov. 2, the Centers for Medicare & Medicaid Services (CMS) published the CY 2022 Medicare Physician Fee Schedule (PFS) Final Rule, which includes the final policies for the 2022 performance year of the Quality Payment Program (QPP).
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The changes to performance category weighting and performance thresholds are in line with MACRA legislation requirements for the 2022 performance year. Included in the final rule are details for MIPS Value Pathway (MVP) scoring and the first list of approved MVPs for the 2023 performance year, including a rheumatology MVP submitted by the ACR. Notably, the CMS is also thinking of sunsetting traditional MIPS by the end of the 2027 MIPS performance year/2029 MIPS payment year in favor of MVP and Alternative Payment Model (APM) participation. Lastly, a major takeaway is that avoiding a penalty in MIPS will become harder, because the performance threshold will be increased to 75 points and quality bonus points will be removed.
The ACR RISE registry staff reviewed the final rule and highlight below critical policy changes for the 2022 MIPS reporting period. You are also encouraged to check out the ACR Overview of 2022 Medicare Physician Fee Schedule Final Rule. If you have questions or concerns about how these proposed changes may affect your practice, contact RISE staff at [email protected].
Performance Category Weights
- Quality: 30% for PY 2022 (40% for PY 2021)
- Cost: 30% for PY 2022 (20% for PY 2021)
- Promoting Interoperability: 25% for PY 2022 (no change from PY 2021)
- Improvement Activities: 15% for PY 2022 (no change from PY 2021)
- Performance threshold: 75 points (60 points for CY 2021)
- Additional performance threshold for exceptional performance: 89 points (85 points for CY 2021)
The CMS notes that the 2022 performance year/2024 payment year is the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.
Quality Performance Category
Beginning with the 2022 performance period, there are no bonus points for reporting additional outcome and high priority measures beyond the one required. In addition, there are no bonus points for measures that meet end-to-end electronic reporting criteria.
The CMS will also remove the three-point floor for scoring measures, with some exceptions for small practices, beginning with the 2023 performance period. Lastly, the CMS updated the quality measure inventory, and there are a total of 200 quality measures available for the 2022 performance period.
Quality Performance Category Collection Types
The CMS is extending the CMS Web Interface as a collection type and submission type in traditional MIPS for registered groups, virtual groups and APM Entities with 25 or more clinicians for the 2022 performance year.
Quality Measure Benchmarks
After analyzing the available data, the CMS determined there was no need to use performance benchmarks exclusively or to use a different baseline period (such as CY 2019) to create historical benchmarks. The CMS will create historical benchmarks for the 2022 performance period, using data submitted for the 2020 performance period.
Improvement Activities Performance Category
The CMS is:
- Adding seven new improvement activities, three of which are related to promoting health equity
- Modifying 15 current improvement activities, 11 of which address health equity
- Removing six previously adopted improvement activities
Promoting Interoperability Performance Category
Public Health and Clinical Data Exchange Objective
The CMS is modifying the reporting requirements for the Public Health and Clinical Data Exchange Objective and requiring MIPS-eligible clinicians to report the following two measures (unless an exclusion can be claimed):
- Immunization Registry Reporting
- Electronic Case Reporting
Beginning with the 2022 performance period, the following measures are optional; clinicians, groups and virtual groups that report a “yes” response for any of these measures will earn five bonus points:
- Public Health Registry Reporting measure
- Clinical Data Registry Reporting measure
- Syndromic Surveillance Reporting measure
Promoting Interoperability Measures
- The CMS did not finalize the proposal to modify the Provide Patients Electronic Access to Their Health Information measure to require patient health information to remain available to the patient (or patient-authorized representative) indefinitely, starting with a date of service of Jan. 1, 2016.
- The Safety Assurance Factors for EHR Resilience Guides (SAFER Guides) is a new, required measure in which MIPS-eligible clinicians must attest to conducting an annual assessment of the High Priority Guide of the SAFER Guides.
- For the Electronic Case Reporting measure, the CMS is adding a fourth exclusion (in addition to the existing exclusion criteria) for PY 2022 only: Uses certified electronic health record technology (CEHRT) that isn’t certified to the electronic case reporting certification criterion at 45 CFR 170.315(f)(5) prior to the start of the performance period they select in CY 2022.
The CMS modified the required Prevention of Information Blocking attestation statements.
Promoting Interoperability Reweighting
In addition to the existing special statuses/clinician types, the CMS will apply automatic reweighting to the following, beginning with the 2022 performance period:
- Small practices
- Clinical social workers
Cost Performance Category
The CMS is adding five newly developed episode-based cost measures into the Cost performance category.
The CMS is maintaining the current data completeness threshold at 70% for the 2022 and 2023 performance periods.
Redistributing Performance Category Weights for Small Practices
The CMS is finalizing the following performance category reweighting and redistribution policies for small practices to put more emphasis on the Improvement Activities performance category:
- When the Promoting Interoperability performance category is reweighted:
- The Quality performance category will be weighted at 40%;
- The Cost performance category will be weighted at 30%; and
- The Improvement Activities performance category will be weighted at 30%.
- When both the Cost and the Promoting Interoperability performance categories are reweighted:
- The Quality performance category will be weighted at 50%; and
- The Improvement Activities performance category will be weighted at 50%.
Under the existing policies, when both Quality and the Promoting Interoperability performance categories are reweighted, the Cost and Improvement Activities performance categories will be equally weighted at 50%.
MIPS Value Pathways (MVPs)
One of the seven MVPs starting with the 2023 performance period/2025 MIPS payment year is Advancing Rheumatology Patient Care, created by the ACR. Through this MVP, rheumatology providers can choose among quality measures relevant to rheumatology and improvement activities that have been vetted by rheumatology experts.
The table below lists the measures and activities that are finalized within the Advancing Rheumatology Patient Care MVP.
|Q111: Pneumococcal Vaccination Status for Older Adults||IA_AHE_3: Promote use of Patient-Reported Outcome Tools||Total Per Capita Cost (TPCC)|
|Q130: Documentation of Current Medications in the Medical Record||IA_BE_4: Engagement of patients through implementation of improvements in patient portal|
|Q176: Tuberculosis Screening Prior to First Course Biologic Therapy||IA_BE_15: Engagement of patients, family and caregivers in developing a plan of care|
|Q177: Rheumatoid Arthritis (RA): Periodic Assessment of Disease Activity||IA_BMH_2: Tobacco use|
|Q178: Rheumatoid Arthritis (RA): Functional Status Assessment||IA_BMH_4: Depression screening|
|Q180: Rheumatoid Arthritis (RA): Glucocorticoid Management||IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record|
|ACR12: Disease Activity Measurements for Patients with PsA||IA_EPA_2: Use of telehealth services that expand practice access|
|ACR14: Gout Serum Urate Target||IA_PM_16: Implementation of medication management practice improvements|
|ACR15: Safe Hydroxychloroquine Dosing||IA_PSPA_6: Consultation of the Prescription Drug Monitoring Program|
|IA_PSPA_28: Completion of an Accredited Safety or Quality Improvement Program|
These are key takeaways from the 2022 Final Rule; not all changes have been included in this overview. To learn more about the PFS Final Rule and the 2022 QPP finalized policies, review the following resources:
- Press Release
Provides additional details regarding the announcement.
- 2022 Quality Payment Program Final Rule
This is a link to the CY2022 Medicare Physician Fee Schedule (PFS) Final Rule.
- 2022 Quality Payment Program Resources
This zip file includes the 2022 QPP final rule overview fact sheet; a policy comparison table; MVPs policy table; a MVP development standardized template; and FAQs.
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail [email protected].
ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE registry at 404-633-3777 or by email at [email protected].