By Emily Fahey
CMS has once again moved the proverbial MIPS cheese. Numerous programmatic modifications to the MIPS Quality category are leaving many practices feeling lost, frustrated, and staring down the barrel of markedly lower MIPS scores than in previous years.
Quick review of the 2022 changes: the Quality category is lowered to 30% of the overall MIPS score, on parity with Cost (also now 30%) as legislatively required by Congress. Within the Quality category, High Priority, Outcome and End to End bonus points are no longer available. The Promoting Interoperability (PI) category had a few updated measure requirements as well (Immunization Registry Reporting and Electronic Case Reporting). The Complex Patient Bonus formula was updated to target practices/ providers who see medically and/or socially complicated patient populations, meaning not every practice will receive a CPB for 2022.
Now, back to our regular, Quality-centered programming. Without Quality bonus points in 2022, practices’ strategic approach must adjust to adapt and overcome. With HP/O, and E2E no longer padding Quality scores to close performance gaps, where should you turn to next to make sure your practice scores above the 75-point penalty threshold? The answer is calculated measure selection!
As the MIPS program heads into its later years, measure selection is more important than ever for reporting success and will continue to be for future years. How do practices navigate these uncharted waters? By working closely with ReportingMD experts.
For new measures introduced in 2022 and beyond, there is now a 7-point floor the first-year performance year. The second year after a measure is introduced there is a 5-point floor. Unfortunately, CMS only released three new measures for the 2022 reporting period, so few practices or clinicians can take advantage of this new value.
The following should play a role in selecting the best measures for your practice:
The pandemic may have taken the teeth out of some aspects of MIPS by allowing the Extreme & Uncontrollable Circumstances application to remain for 2022, however, failure is intended with the MIPS track of the QPP. It’s built into the program’s framework. Without penalties there are no incentive adjustments with this zero-sum plan. Being thorough in your decision making on measure selection by understanding measure requirements, comparing benchmarks, and executing on measure processes and workflows that support good quality performance, may mean the difference between a penalty and incentive. Even more is changing on Quality measure scoring in 2023 but that’s a blog for another time.
Make sure to consult with your Dedicated Advisor for benchmarking help and measure selection guidance.