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CMS Changed the Rules Again – Now What? A Guide to Measure Selection for Success

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:

  • Choose applicable measures to your practice’s specialty
    1. This sounds simple but you’d be surprised
    2. Broad measures such as alcohol use and cessation or documentation of current medications can also work well for specialties that have a difficult time finding reportable measures
  • Select measures that are currently internally tracked and monitored or reported out to third party payers. Having data collection systems in place to know what the practice’s performance rate might be can go a long way in successful measure selection and higher scores.
  • Select measures you know the practice performs the clinical action. If you are selecting measure 226 (tobacco cessation), make sure clinical staff actually counsel tobacco using patients on quitting tobacco. (This is not the best measure for a pathology group).
  • Be mindful of benchmarks. If you are intrigued by a new measure, it will no longer bite back to try it. With the 7-point floor adding a new measure will not automatically present the practice with only 3 points for that given measure.
    1. Consider reporting method when it comes to performance and benchmarks
      1. Medicare part B claims. It is the black hole method of reporting. Practices can see there are established benchmarks. However, there is no insight into your own performance rate and score until after you submit.
      2. Registry / MIPS CQM – this reporting method has the broadest range of measures though the benchmarking may not always be the best option when compared to…
  • EHR/ eCQM – EHR usually has the better benchmarks of reporting though fewer measures to report on.
  • Avoid measures that are topped out or have a seven-point cap or opt to not report these measures to CMS if they are important to your organization
  • Choose measures that the practice performs at least 20 eligible encounters for over the year, ensuring the practice will score beyond the three-point floor.
  • Use the resources RMD and CMS have available. Specialty practices may struggle to find six measures to report on. CMS releases EMA Clusters (Eligible Measure Applicability) annually, which list specialty measure sets to provide ideas as well as assistance to practices that do not have enough measures to report.

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.