The Centers for Medicare and Medicaid Services (CMS) has released the Quality Payment Program (QPP) proposed rule for the 2022 performance year. Here are the highlights of the proposed rule for next year. For information on the current performance year, see our MIPS 2021 page.
You can view the full proposed rule and fact sheet on the QPP website.
MIPS Value Pathways (MVPs)
In 2019, CMS announced a plan to transition to MIPS Value Pathways, a new framework intended to create measure sets more relevant to clinician scope of practice and more meaningful to patient care by connecting MIPS measures across the four performance categories specific to specialty or condition.
CMS is proposing to begin this transition starting in the 2023 performance year, with seven MVPs available initially for the following clinical topics.
- Stroke Care and Prevention
- Heart Disease
- Chronic Disease Management
- Emergency Medicine
- Lower Extremity Joint Repair
Additionally, with this launch of MVPs in 2023, CMS is proposing to create a new subgroup reporting type for multispecialty groups.
CMS proposes the addition of Certified Nurse Midwives and Clinical Social Workers to the list of MIPS-eligible clinician types.
In 2022, the Quality and Cost performance categories will each be weighted at 30%.
Last year, CMS announced its intent to end the CMS web interface as a measure collection and submission type in 2022. CMS now proposes to extend this date and instead end the use of the CMS web interface for collection and submission starting in 2023.
CMS proposes quality measure inventory updates, including five new quality measures and the removal of 19 measures. They also propose updates to individual measure scoring policies based on benchmark and case minimums.
CMS proposes five new episode-based cost measures. They also propose adding scoring flexibility for external factors that impact cost measures, such as the public health emergency.
Promoting Interoperability Category
CMS proposes a reweighting process for small practices who do not submit Promoting Interoperability (PI) data. Previously, a hardship application was required in order for reweighting of this category for small practices. Going forward, CMS proposes to reweight this category and distribute the weight to other performance categories automatically when a small practice does not submit PI data.
For Nurse Practitioners, Physician Assistants, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, Certified Nurse Midwives, and Clinical Social Workers, the PI category will be reweighted to zero unless these clinicians submit PI data--if they do submit data, they will be scored in this category.
CMS also proposes new requirements surrounding patient data availability and immunization registry reporting.
Improvement Activities Category
CMS is proposing updates to the Improvement Activities inventory, including the removal of six measures and the addition of seven measures.
New improvement activities must be nominated during the Annual Call for Activities from February 1 to July 1 each year. Starting in 2022, CMS proposes an exception that allows for activities to be nominated outside of this established timeframe during public health emergencies.
CMS also proposes two new criteria for proposed activities:
- They must not duplicate any other activities in the inventory
- They should drive improvements that go beyond standard clinical practices
For the 2022 performance period, CMS proposes to increase the performance threshold (maximum number of points needed to avoid a negative payment adjustment) from 60 to 75 points.
The proposed exceptional performance threshold (number of points needed for a positive payment adjustment) will increase from 85 to 89 points. The 2022 performance year is the last year of the additional performance threshold and the associated additional MIPS payment adjustment factors for exceptional performance.
CAHPS for MIPS
CMS proposes changes to the CAHPS for MIPS survey process starting in 2022.
It is proposed that patients surveyed for the ICH CAHPS survey will be excluded from CAHPS for MIPS sampling in order to increase ICH CAHPS response rates and reduce patient survey burden.
Case Mix Adjustment
In addition to the current six case mix adjusters for CAHPS for MIPS, CMS proposes to add a seventh “Asian language survey” adjuster.
The Access to Specialists measure was previously excluded from scoring and benchmarking due to low reliability and response rates. CMS proposes this measure will once again be scored and benchmarked starting in 2022.
MIPS and SurveyVitals