Blog

Calendar year (CY) 2022 Physician Fee Schedule Final Rule Highlights for MIPS and Quality

Below are some highlights from the CY2022 Physician Fee Schedule Final Rule:

• MIPS Value Pathways (MVPs) will be available for reporting in performance year 2023.
• Clinical Social Workers and Certified Nurse Midwife are eligible clinicians in Performance Year (PY) 2022.
• Extending the CMS Web Interface as a collection type and submission type in traditional MIPS for registered groups, virtual groups and APM Entities with 25 or more clinicians for the 2022 performance year. 
• Will create historical benchmarks for the 2022 performance period, using data submitted for the 2020 performance period.

Scoring

The maximum negative payment adjustment for PY2022 is -9%. The actual adjustment you’ll receive in the 2024 payment year will be based on your MIPS final score from the 2022 performance year and is subject to a scaling factor to ensure budget neutrality, as required by MACRA.

Final Scoring

Complex Patient Bonus

• The complex patient bonus will be limited to clinicians who have a median or higher value

for at least 1 of the 2 risk indicators (Hierarchical Condition Category score and proportion

of patients dually eligible for Medicare and Medicaid benefits).

• Clinicians eligible for the complex patient bonus can earn up to 10 bonus points.

Category scoring breakdown: 

Traditional MIPS: Individuals, Groups, Virtual Groups

• Quality: 30% 

• Cost: 30% 

• Promoting Interoperability: 25% (no change) 

• Improvement Activities: 15% (no change) 

Traditional MIPS: APM Entities (no change) 

• Quality: 55% 

• Cost: 0% 

• Promoting Interoperability: 30% 

• Improvement Activities: 15% 

APP: Individuals, Groups, APM Entities (no change) 

• Quality: 50% 

• Cost: 0% 

• Promoting Interoperability: 30% 

• Improvement Activities: 20%

Small Practices

Small Practices are automatically reweighted to 0% for Promoting Interoperability (PI), regardless of whether they choose to participate as individuals or as a group. If data is submitted, it will be scored. 

• If PI is 0%, quality will be weighted at 40%, cost weighted at 30%, and improvement activities at 30%

Accountable Care Organizations (ACO)

ACOs will still be able to use the CMS web interface to report 10 quality measures in 2022, 2023, and 2024 performance years under the APP.  The CMW web interface will sunset in 2024 and all ACOs will be required to report the 3 eCQMs/MIPS CQMs beginning in 2025.

Quality Performance Category Updates

• Removed end-to-end electronic and high-priority/outcome measure bonus points.

• New quality measures will have a 7-point floor for their first year in the program, and a 5-

point floor for their second year in the program.

Improvement Activities Performance Category Updates

 • In the case of an improvement activity for which there is a reason to believe that the continued collection raises possible patient safety concerns or is obsolete, the improvement activity will be suspended.

Promoting Interoperability Performance Category Updates

Public Health and Clinical Data Exchange Objective 

We’re modifying the reporting requirements for this objective and requiring MIPS eligible clinicians to report the following 2 measures (unless an exclusion can be claimed): 

• Immunization Registry Reporting 

• Electronic Case Reporting

Beginning with the 2022 performance period, the following measures are optional; clinicians, groups and virtual groups that report a “yes” response for any of these measures will earn 5 bonus points: 

• Public Health Registry Reporting measure 

• Clinical Data Registry Reporting measure 

• Syndromic Surveillance Reporting measure

Safety Assurance Factors for EHR Resilience Guides (SAFER Guides) 

• New required measure 

• MIPS eligible clinicians must attest to conducting an annual assessment of the High Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides).

Electronic Case Reporting 

• We’re adding a 4th exclusion (in addition to the existing exclusion criteria) for PY 2022 only.

Cost Performance Category Updates

Added 5 newly developed episode-based cost measures into the MIPS cost performance category beginning with the 2022 performance period.

• 2 procedural measures:

--- Melanoma Resection

--- Colon and Rectal Resection

• 1 acute inpatient measure:

--- Sepsis

• 2 chronic condition measures:

--- Diabetes

--- Asthma/Chronic Obstructive Pulmonary Disease [COPD]

Sources

CY 2022 PFS Final Rule QPP Comparison Tables

CY 2022 PFS Final Rule QPP External FAQs

CY 2022 PFS Final Rule QPP MVPs Policies Table

CY 2022 PFS Final Rule QPP Overview Fact Sheet