2022 MIPS Proposed Rule – PT 2: MVPs, Appropriate Use & EPCS Medicare Part D Proposals

Welcome to our second and final installment of this blog series on important changes in the 2022 Physician Fee Schedule (MIPS Proposed Rule). In Part 1, we took a look at key changes to the Quality Payment Program (QPP). In this blog, we will summarize the new MIPS Value Pathways (MVPs) as well as important changes to the Appropriate Use Criteria and EPCS Medicare Part D Compliance Requirements.

Quality Payment Program Introduction to MIPS Value Pathways (MVPs)

The introduction of MVPs to the Quality Payment Program has been in MIPS proposals for at least a couple of years already. The overall goal of these MVPs is to align and streamline measures/activities across specialties. If they actually make it into the final rule this time, the first seven MVPs would go into effect beginning in the 2023 Performance Year and will align with the following specialties:

1. Rheumatology
2. Stroke Care & Prevention
3. Heart Disease
4. Chronic Disease Management
5. Emergency Medicine
6. Lower Extremity Joint Repair
7. Anesthesia

The proposed MVP requirements are listed below.

• Foundational layer: One Population Health measure and a Performance measure for Promoting Interoperability (which will be the same as traditional MIPS)
• Quality Performance: Four Quality measures including one Outcome measure
• Improvement Activities: Choose between two medium-weighted activities or one high-weighted activity
• Cost Performance: This will be calculated by CMS based on the respective Episode-Based Cost measure included in the MVP

Appropriate Use Criteria Requirements

Proposed changes to Appropriate Use Criteria (AUC) requirements are as follows:

• Proposed Payment Penalty Phase
  • The earliest that the AUC claims processing system can begin screening claims for compliance and determining payment penalty would be October of 2022
  • Therefore, the proposed effective date for ACU claims processing edits and payment penalty phase would be Jan 1, 2023
  • Claims that do not properly include AUC consultation information will not be paid once AUC claims processing edits are fully implemented.
• There is a proposal to exclude claims in which Medicare is the secondary Payer

EPCS Medicare Part D Compliance

Proposed changes to EPCS Medicare Part D Compliance are as follows:

• A proposal to push back the compliance deadline to Jan 1, 2023
• The defines compliance as prescribing at least 70 percent of Part D controlled substance prescriptions electronically per calendar year (to be calculated by examining PDE data for each year where # of EPCS/total # of controlled substances prescribed by provider)
• Proposed penalties for the 2023 Performance Year will consist of letters to providers; there would be no monetary penalties if this makes it into the final rule

Thanks for joining us on this exploration of the 2022 Proposed Rule. We expect the final rule to be published sometime in November. Subscribe to this blog in order to keep yourself informed on the final rule as well as other compliance and regulatory updates!

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