Recently, the Centers for Medicare and Medicaid services released a new proposal of the Medicare physician fee schedule for 2022; this may mean big changes to all requirements for 2022. The final ruling is expected to be set by November 1st of this year. This new proposal is expected to make a more easily accessible and inclusive health care system.
This proposal includes changes to the Merit-based Incentive Payment System, more commonly known as MIPS. MIPS is a program that allows eligible clinicians to receive a bonus in payments, or a penalty on their payments, based on their performance score. The performance model’s threshold will be set at 75 points, while the threshold for exceptional performance will be placed at 89 points. Changes proposed may also include the options for participation for the Alternative Payment Model, APM for short. APM is a way to incentivize affordable quality care. There could be potential changes in payment rates using a conversion factor, that would decrease just under 4% from 2021 rates.
Another change to note would be the delay of the payment penalty phase of the Appropriate Use Criteria (AUC) until 2023, or until the end of COVID-19 health emergency – whichever comes later. AUC is a criterion in which procedures can be determined if they are suitable for the patient or not, expecting that the medical gains significantly outweigh the medical risks. With reference to COVID-19, these changes will allow the continuation of audio-only visits for mental health services. This proposal is hoping to extend the CMS web interface in order to allow collections and submissions.
One final topic to note is the setting of 2023 as the first year that will follow the new MIPS Value Pathways (MVPs). MVPs are predetermined measures and activities that allow eligible clinicians to meet the MIPS requirements with guidance. With this change, in 2023, it will allow more to participate in the program; i.e. clinical social workers and certified nurse midwives. The list continues as they plan to include these select clinical topics: rheumatology, stroke care and prevention, heart disease, chronic disease management, emergency medicine, lower extremity joint repair, and anesthesia. As of now there is no policy in place on how to remove activities that raise possible safety concerns for patients, so in addition to adding to the list of approved activities, this proposal allows some to be removed. There is already a program in place to reweight to MIPS eligible clinicians, and along with allowing more clinicians to register for the program, they plan to apply automatic reweighting for them as well. Currently, smaller practices with 15 or fewer eligible clinicians, can apply for an exemption for hardship, that way the reweighting can be applied to a different performance category.
Changes to quality reporting are going to continuously grow in ways that allow more medical affiliates to report. Currently, Care Compare allows quality reporting to be displayed for hospital affiliations, which then links the corresponding office to that report. Moving forward, this proposal expects to add more facility types, including but not limited to: inpatient rehab centers, hospice, and skilled nursing facilities. In addition to those joining the program, there are also reporting requirement additions to note. Reports under the foundational layer will need to include population health measures and promotions of the interoperability performance category. Under the quality performance category, MVP participants will need to select 4 quality measures, which would have to include an outcome measure; this can be measured by CMS through administrative claims (if available). Additionally, the improvement activities performance category requires participants to choose 2 medium-weighted improvement activities, or one high-weighted activity of the same nature. Furthermore, another area of reporting comes from the cost performance category. CMS calculates a facility’s performance solely on the cost measures that are apart of the MVP administrative claims data. For specifics on how CMS will score these categories, please follow the link below. For a quick look at reporting requirements, registration deadlines, and the information required when registering, please read over the tables below provided by CMS.
For more information regarding this proposal, please direct your attention to the following links.
“Medicare Proposes 2022 Payment and Quality Reporting Changes.” MGMA,