The final rule was released on November 2, 2021 and brought with it good news and bad. The bad news first. Although CMS did not finalize the policy to remove the 3-point quality measure scoring floor for 2022, they did finalize the removal of the end to end and additional outcome/high priority quality bonus points.
This finalized policy will decrease MIPS quality scores by up to 20%; even more in cases where other categories are reweighted.
So now the good news… MIPS participants that have sought to improve performance across the categories of EHR/PM technology interoperability, quality improvement activities, cost reduction, and quality performance will come out on top in 2022.
Those that have worked with experts to understand how best to convey their quality care excellence through sound measure selection for optimal scoring may finally reap the rewards they have been working towards since the start of the program.
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.
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, will certainly be a challenge to reach but will also be the reason why incentives could be so high from 2022.
The numbers are there to back up the realistic possibility that a MIPS participating practice or clinician that reaches a perfect MIPS score of 100 in 2022 may experience a 14.4% upward payment adjustment on all Medicare professional services billed throughout 2024.
Those without a well refined plan to achieve the 75 point threshold will likely be the ones footing the bill for an exceptional upward payment adjustment.
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