For the last few years, MIPS (Merit-Based Incentive Payment System) has been avoidable primarily due to COVID-19 and other hardships. However, 2022 seems to be the year when there is going to be pushback on the practices making it more difficult to get an exemption. It is important to understand the main changes that have been implemented that could potentially raise issues for practices who aren’t prepared. It is also important to understand the differences between attesting as a group or an individual.
In the past, the threshold to avoid a penalty (for 2022 the penalty stays the same at +/- 9%) has been 60 points, covering 4 categories including quality, cost (which is the biggest culprit for 2022), interoperability and promoting interoperability. The new threshold will be 75 points, with the cost category accounting for 30% of that number. Where that becomes tricky is that the cost category is not calculated in you EHR dashboard. It is calculated from your claims data. If that is not something you know how to calculate, it could lead to a dangerous situation at the end of the year.
- Data Completeness – MIPS eligible clinicians will continue to meet the current data completeness threshold of 70%.
- Measures with a benchmark – The 3-point floor is removed for measures that can be scored against a benchmark. These measures will receive 1-10 points.
- Measures without a benchmark – The 3-point floor is removed for measures without a benchmark. These measures will receive 0 points (small practices will continue to earn 3 points).
- Measures that don’t meet case minimum requirements (20 cases) – The 3-point floor is removed except for small practices.
- Bonus Points – Bonus points will no longer be awarded in 2022 for end-to-end (ETE) electronic reporting and reporting additional Outcome/High-priority measures beyond the required measures
- Quality Measures – There are 200 Quality measures available for the 2022 performance period. This includes substantive changes to 87 existing Quality measures, four new Quality measures (including 1 new administrative claims measure), and removal of 15 existing Quality measures, (two are applicable to Medicare Part B Claims only).
- For the 2022 performance year CMS is adding seven new activities and modifying 15 current activities.
- Many of the changes pertain to health equity and standardizing language related to equity across the activities.
- There are six activities that will be removed from the IA inventory.
- The Final Rule will also allow CMS to suspend an Improvement Activity if there is a reason to believe that the continued collection raises possible patient safety concerns or is obsolete.
- A new required measure called the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides) will be adopted.
- This measure requires MIPS eligible clinicians to attest to conducting an annual assessment of the SAFER Guides beginning with the 2022 performance period.
Make sure you understand your EMR. Is your dashboard set up correctly?
HCN trained and credentialed compliance specialists are prepared to help our clients adjust to the shifting regulations. To learn more about how to protect yourself from potential MIPS penalties please contact us at hcompliance.com or (855) 526-6754.