2022 MIPS Proposed Rule – PT 1: Quality Payment Program Proposals

Back in mid-July, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2022 Physician Fee Schedule. In this two-part blog series, we are going to take a look at some of the more notable changes in the 2022 MIPS proposed rule. In this first installment, we will be summarizing the proposed changes to the 2022 Quality Payment Program.

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Proposed MIPS 2022 General Program Changes

Here is a list of some of the proposed changes to the overall MIPS 2022 Program:

• Performance Category weights for quality and cost will both be 30 percent per statutory requirements with Promoting Interoperability and Improvement Activities staying at their weights of 25 percent and 15 percent respectively.
• Complex Patient bonus continuing to double to 10 points when applicable to the patient.
• The MIPS Performance Thresholds, as required by statue, will be the mean final score from the 2017 performance year. Therefore, the performance threshold (minimum to avoid penalty) will be 75 points. The exceptional performance threshold will be set at 89 points.

Proposed Quality Category Changes

Important proposed changes to the Quality Improvement Category are as follows:

• Data Completeness stays at 70 percent for 2022 performance year but is proposed to increase to 80 percent for 2023.
• Removal of the 3-point floor for measures that can be scored against a benchmark
• Removal of the 3-point floor for measures without benchmarks
  • These measures would be worth 0 points with the exception of small practices – they would continue to receive 3 points.
• Any new measures added would have a 5-point floor for the first two years
• Eliminating Bonus points:
  • High-Priority bonus points would not apply to measures beyond the 1 required
  • End-to-End bonus points would not apply to measures reported electronically

Proposed Cost Category Changes

Some of the most notable proposed changes to the Proposed Cost Category are as follows:

• Five new episode-based cost measures have been proposed:
  • 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)

Proposed Improvement Activities Category Change

The only noteworthy change to this category (for our readers) is the addition of seven new improvement activities, three of which are related to promoting health equity.

Proposed Promoting Interoperability Category Change

Important proposed changes to the Promoting Interoperability Category are as follows:

• Require reporting (unless exclusion can be claimed) for the following Public Health and Clinical Data Exchange Objectives:
  • Immunization Registry Reporting
  • Electronic Case Reporting
• New measure that indicates providers/practice attest (Y/N) to an annual assessment of the High Priority Guide of the Safety Assurance Factors for HER Resilience Guides (SAFER Guides)

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