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 MIPS Value Pathways (MVPs) and the Alternative Payment Model Performance Pathway in the upcoming weeks (APP).
This post will help familiarise you with the Traditional MIPS changes coming in 2022 and help you be ready for the impending switch to MVPs.
Traditional MIPS: new documentation needs
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:
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).
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 and preventive care: Screening and Intervention for Tobacco Use
MIPS REQUIREMENTS FOR CLINICAL SOCIAL WORKERS AND PROMOTING INTEROPERABILITY
Promoting Interoperability (PI) is one of four categories that make up satisfying MIPS, as was previously mentioned. Clinical social workers* may automatically reweight their PI score to zero and distribute their overall MIPS scoring according to the following, according to CMS:
CONSIDERATIONS FOR THE MIPS OF CERTIFIED NURSE-MIDWIVES
Advanced practice registered nurses (APRNs) with a certification in midwifery is known as certified nurse-midwives (CNMs). Since they are APRNs, they have greater clinical obligations than registered nurses and can write prescriptions for drugs (RNs).
alterations to the MIPS score overall
by class: 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.)
performance benchmarks The minimum performance threshold for ECs will increase from 60 MIPS points in 2021 to 75 MIPS points in total starting in 2022.
The mean final score in the CY 2017 PP was 75 points (2019 payment year). This satisfies the criteria set forth by CMS, which calls for ECs to adopt a performance criterion for 2022 that is equal to the average or median of all ECs’ final MIPS scores for a previous 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.
Category: Promoting Interoperability
In addition to the PI criteria for 2021, Traditional MIPS has new reporting requirements for the performance year 2022.
EXCHANGE OF CLINICAL AND PUBLIC HEALTH DATA
In keeping with CMS’s dedication to helping public health organizations recover over the long term from COVID-19 and in the face of potential future health threats:
CMS will now mandate that ECs submit reports to the Electronic Case Reporting and Immunization Registry (unless they can take an appropriate exclusion). You should also take note that CMS has added a fourth exclusion to the Electronic Case Reporting for 2022 only, namely, “Uses certified electronic health record technology (CEHRT) that isn’t certified to the electronic case reporting certification criteria prior to the beginning of the performance period they select for 2022.”
The Public Health Registry, the Syndromic Surveillance Reporting, and the Clinical Data Registry are now optional. Clinicians who attest to any of the three registries with a “Yes” response and are MIPS-eligible will receive a 5-point bonus. (However, you will only receive the initial 5-point bonus if you attest “Yes” to two or three of the registries.)
SAFER GUIDE, ALSO KNOWN AS THE “SAFETY ASSURANCE FACTORS FOR EHR RESILIENCE GUIDES,” IS A NEWLY REQUIRED MEASURE.
Beginning with the 2022 MIPS performance year, this new measure mandates that MIPS-eligible doctors certify to undertake an annual assessment of the SAFER Guides. The guides’ main goal is to offer best practices for enhancing the security and responsible use of EHRs. The guides are broken down into three main categories: foundational guides, infrastructure guides, and guides for clinical processes.
IMPERATIVE TO “GIVE PATIENTS ELECTRONIC ACCESS TO THEIR HEALTH INFORMATION”
For visits on or after January 1, 2016, patients must be given prompt access to view, download, or transmit their health information online.
Category of Improvement Activities
In the performance year 2022, CMS is keeping:
Six earlier IAs have been withdrawn by CMS.
In order to improve healthcare equity and access to high-quality, patient-centered care in 2022, CMS is still committed to its strategic goal of fostering innovation. The numerous IA modifications made to address equality issues, the expansion of telehealth services, the usage of audio visits, the expansion of access to physicians’ assistants through billing changes, and other initiatives all serve as examples of this dedication.
NEW POLICY TO STOP ACTIVITIES FOR IMPROVEMENT AS NECESSARY
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.
UPDATES TO THE QUALITY PERFORMANCE CATEGORY’S SCORING
There are several scoring adjustments for the Quality category starting in 2022:
updated quality metrics If a performance benchmark cannot be established for new Quality measures, the measure will receive 7 points in the first PP and 5 points in the second PP if the minimal conditions for data completeness and cases are met (see below).