You may have heard that the “Traditional MIPS” component of the Merit-based Incentive Payment System (MIPS) would be phased out by 2027.The current Traditional MIPS program will undergo significant modifications in 2022 as CMS moves toward two new “Pathways” programs that will eventually replace Traditional MIPS. Watch for future blog postings describing CMS’s initiatives to improve the value and quality of patient care using the Value Pathways (MVPs) and the Alternative Payment Model Performance Pathway in the upcoming weeks (APP).
This post will help familiarize you with the Traditional MIPS changes coming in 2022 and help you be ready for the impending switch to MVPs.
Traditional MIPS: revised reporting specifications
Traditional MIPS, which was created in the first year of the Quality Payment Program (QPP) of the Centers for Medicare and Medicaid (CMS), is the original framework that is still accessible to MIPS-eligible providers today for acquiring and reporting performance data metrics across four areas: Activities for Promoting Interoperability (PI) and Quality Improvement
Until they opt to use the new APP (available in 2022) or the new MVP framework, physicians who are cost-eligible for MIPS registry 2022 will be able to use the Traditional MIPS framework (available beginning in 2023).
Clinicians are now regarded as MIPS-eligible under two New Provider Types:
- Clinicians in social work
- Licensed nurse-midwives
Why it’s significant:
In order to comply with the definition of eligible clinicians in the Alternative Payment Model (APM), CMS suggested the following additions. A clinician who qualifies for the QPP under MIPS or other CMS programs that use electronic clinical quality measures (eCQMs) for quality reporting, such as APM participants, is referred to as an eligible clinician (EC).
Clinical social workers and/or certified nurse-midwives who work for your practice must set up new provider workflows to collect the MIPS-required data items. You can start reporting for these new provider types with the aid of the Practice Fusion EHR.
CONSIDERATIONS FOR CLINICAL SOCIAL WORKERS IN THE MIPS
Although clinical social workers were exempt from MIPS reporting requirements in the 2020 and 2021 PPs, CMS still introduced a finalized Clinical Social Work MIPS Specialty Measure Set for 2021 to aid these providers in preparing for the performance year 2022 when they would be added to the list of MIPS-eligible clinicians.
The Social Work MIPS Specialty Measure Set contains what specific Quality measures? Early in 2022, CMS plans to publish the approved Quality Measures for the Social Work Specialty Measure Set. As a result, some of the policies approved for 2022 may be slightly different from those decided upon for 2021. The following items are part of the finalized 2021 Measure Set:
Two Quality Measures have been added to the initial set of Quality Measures:
- Current Medication Information in the Medical Record Screening
- Preventive Care: Screening and Intervention for Tobacco Use
Alterations to the MIPS score overall
The law stipulates that the Quality and Cost categories in the QPP program must be equally weighted at 30% each as of the 2022 PP. The percentages for the PI and Improvement Activity (IA) categories remain at 25% and 15%, respectively, from CY 2021. (As mentioned above, small practices and clinical social workers have their PI categories weighted to zero as an exception.)
The minimum performance threshold for ECs will increase from 60 MIPS points in 2021 to 75 MIPS points in total starting in 2022.
the middle or average of all of EC’s final MIPS ratings for a prior PP.
Additionally, MIPS-eligible physicians must achieve a score of >89 points in order to qualify for the Exceptional Performance incentive for their performance in 2022. CY The final year that participating providers will be eligible to receive an Exceptional Performance incentive is 2022.
Starting in 2023, the program will only be paid for by penalties. It is anticipated that more doctors may see negative payment adjustments as the program requirements increase in difficulty.
Price range in 2022
CMS used expense metrics to assess the following for the year 2021:
- Medicare consumers received total per-capita costs (TPCC), with a primary focus on Primary Care.
- Medicare expenditure per beneficiary (MSPB) clinician
- The price of goods and services delivered across 18 episodes of care to Medicare beneficiaries
Category of quality in 2022
To be consistent with CMS’s plans for scoring the new MIPS Value Pathways, starting in 2022, CMS is recommending a number of adjustments to the Traditional MIPS Quality Measure Scoring (MVPs). To provide physicians, EHR vendors, payers, and other third parties enough time to prepare, CMS will gradually roll out the MVPs starting with the 2023 performance year.
CMS WILL USE A DIFFERENT BASELINE PERIOD DUE TO COVID-19.
The whole calendar year will continue to be the reporting period for Quality in 2022.
The COVID-19 public health emergency (PHE) has resulted in unmanageable and extraordinary circumstances, so CMS is recommending the adoption of a new baseline period as performance period standards, such as the calendar year 2019, awaiting evaluation of the 2020 PP data.
For CY 2022, there are new, modified, and retired quality measures.
For the 2022 performance period, there are about 200 Quality measures that are available for reporting, including over 80 existing Quality measures that have undergone significant changes, one new specialty measure set for certified nurse-midwives, four new Quality measures, and 15 Quality measures that have been eliminated. By 2021, Practice Fusion will support reporting quality measurements using 17 Electronic Clinical Quality Measures (eCQMs).
RETIRING OF THE CMS WEB INTERFACE WAS POSTPONED
Although CMS suggested discontinuing its Web Interface for Traditional MIPS reporting for the 2022 performance year, Accountable Care Organizations expressed serious concern and resisted this (ACOs).
In response, CMS has acknowledged these issues and is currently recommending extending the use of the CMS Web Interface, which depends on data from Medicare beneficiaries, as a collection and submission type for the Traditional MIPS for registered and virtual groups and APMs with more than 25 clinicians through the 2022 performance year.
It’s significant that CMS is now recommending that its Web Interface for Traditional MIPS reporting be retired starting with the 2023 performance year. Following the 2024 performance year, CMS will discontinue the Web Interface for ACOs.