2022 MIPS Cost – How Can Practices Reduce Cost and Improve Cost Scores

When the Quality Payment Program (QPP) under the MACRA legislation kicked off in 2017, the MIPS plan included a phased-in approach to increased challenge in reporting and scoring until a point in which all MIPS eligible clinicians and practices are held responsible for a higher degree of care through improved quality and reduced cost. The CMS “triple aim” was the goal after the QPP’s first few years of development but political backpedaling and a pandemic would move the plan forward one step only to fall back five. While most of the MIPS categories have suffered from the vacillating implementation of the program, the one category that has mostly stayed the course since 2018 is the MIPS Cost category.

Cost wasn’t a scored category until the 2018 MIPS reporting year. CMS has slowly phased in more and more cost measures under the category since the initial year when only 2 measures were included in the Cost score calculation: (1) Medicare Spending Per Beneficiary (MSPB) and (2) Total Per Capita Cost (TPCC). Below shows how CMS phased cost into the scoring from 2018 to 2022:

• 2018 – Cost weighted at 10%
• 2019 – Cost weighted at 15%
• 2020 – Cost not scored during the pandemic
• 2021 – Cost weighted at 20%
• 2022 – Cost weighted at 30%

There is a legislative requirement to have the Cost category be of equal weight to the Quality category starting with the 2022 performance year so Cost is now and will remain at 30% of the MIPS score.

The Cost category does not require any submission as it is calculated by CMS through administrative claims. There are a total of 25 different Cost measures:

• The Medicare Spending per Beneficiary – clinician measure (MSPB-clinician)
• The Total Per Capital Cost measure (TPCC)
• 23 different episode-based cost measures for a variety of procedural and acute inpatient medical condition episodes

The Cost score is the most elusive of the MIPS categories as there is no sure-fire way to improve cost and clinicians subject to its scoring have no control over which measures, they will be scored on. It is solely based on the patients and episodes of care they provide service for and if there are enough to meet the encounter thresholds to get scored on the measure(s). Even though Cost reduction is not directly identifiable, there are ways to reduce cost over time.

• QPP Portal Cost Data – When MIPS participants are scored on cost measures, CMS releases a dataset showing the beneficiaries and episodes that were measured and used for the scoring. Studying that data can help to understand benchmarks and how your costs compare against your peers
• Clinical Documentation Improvement (CDI) – Ensure your clinical documentation conveys to payers the true complexity of your patient population. Work with ReportingMD experts to identify gaps and create methods to better convey patient severity
• ED visits and hospital readmissions – hospital readmissions are a major contributor to higher utilization. Offer enhanced access to providers through after-hours and/or telehealth visits to reduce readmissions
• Annual Wellness Visits (AWVs) – CMS encourages AWVs for Medicare beneficiaries and with good reason. AWVs offer complete diagnostic profiling as well as increased revenue through additional screenings for preventive care
• Patient Care Coordination – Ensure patient referrals and patient information are being shared across all caregivers for each patient

As we enter the sixth year of the MIPS program, the Cost category will likely draw more focus and attention as it will be such a large part of the total MIPS score. Work with organizations that can help you target cost reduction efforts and employ the best tactics to reduce cost using a short and long-term approach.

For 2022, CMS has set the performance threshold, that being the minimum MIPS score needed to avoid penalty, at 75 points, which is the highest it has been so far in the program. CMS also finalized that the exceptional performance bonus would be available for the last time in 2022, which was an extension from the original policy that it would only be paid out the first 5 years of the program. To reach the exceptional performance bonus, MIPS participants must reach a total MIPS score of 89 points. That number, without the inclusion of quality bonus points in the MIPS scores and with the elusive Cost category weighted at 30%, will certainly be a challenge to reach but will also be the reason why incentives could be higher from 2022.