With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Proposed Rule, MIPS participants find themselves wrestling with lingering disappointment from participation in the program in previous years, and resistance to the idea that MIPS will be financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond. This isthesecondin a series ofblog posts on the 2020 payment adjustment and the 2022 Proposed Rule, that will address this sense of disappointment and show how the future of MIPS will contain much more rigorous program requirements andcreategreater financial rewards. To see financial and program success, you will need to be prepared to meet the new challenges. We have the guidance you need to succeed in 2021 and beyond. This blog will review current and upcoming challenges for MIPS reporting and how these challenges make it increasingly difficult to earn the same score and associated payment adjustments as in prior years, even for practices accustomed to earning scores above the exceptional performance threshold.Today, we will focus on changes to the Quality Performance Category. In the chart below, considerthe performance category and final MIPS scoredata from one of our primary care practices in 2018. The practice earned an overall score of85points (exceptional performance). Performance Category Performance Category Points Performance Category Weight MIPS Score (2018) Quality 60/60 50% 50 PI 50/100 25% 13 IA 20/20 15% 15 Cost 7/10 10% 7 Total MIPS Score 85 In 2022, if this practice selects the sameQualitymeasuresand Improvement Activities,and earnsthe same performance pointsin each category, these percentages are projected to yield a lower score of 78%, whichonlynarrowlymeetstheincreasedperformance threshold of 75 points to avoid —just barely—theMIPS payment adjustment.Note,in this example, we are comparing the results from the same measures and activities, with the practice earning approximately the same Quality and IA points for reporting the same measures and activities in 2018 and 2022 (projected results for 2022).2018 MIPS Score for PCP Practice
2022 MIPS Score for PCP Practice | |||
Performance Category | Performance Category Points | Performance Category Weight | MIPS Score (2022) |
Quality | 60/60 | 30% | 30 |
PI | 50/100 | 25% | 13 |
IA | 20/20 | 15% | 15 |
Cost | 20/30 | 20% | 20 |
Total MIPS Score | 78 |
As you can see from the data above, it is the changes in performance category weight, rather than a substantive change in points earned in each category, that is driving the overall change in MIPS final score.
Now that we’ve established a practice that maintains roughly the same performance over multiple performance years will earn a much lower MIPS score in 2022 (approximately 8 points lower in our example above), let’s take a closer look at some of the big picture factors that influenced this change.
Changes inQuality and CostPerformance Category Weights
Starting in 2022, with 100% performance in the three reported performance categories, clinicians cannot be certain that they’ve met the 75% threshold to avoid the payment adjustment without accurately estimating their Cost score, which will be weighted at 30% in 2022. Clinicians can only earn 70% of the MIPSfinalscore in reported categories. In short, not only is it harder to earn points for the Quality performance category, the points earned will make less of an impact on yourtotalMIPS score.
Additionally, the increased emphasis on Cost makes it more challenging to estimate your MIPS Score. Cost is calculated by Medicare Part B claims andcliniciansdo not have access to Cost scoring datauntil Performance Feedback is released.Furthermore,in 2021the Costperformancecategorywas reweighted to 0%, so 2020 Costdatawill not be available in2020FeedbackReports.Clinicians will not be able to utilize that data to make changes or improvements for the 2021 reporting period. The most recentCostdataavailablewill be from 2019 or, for some covid-19 impacted organizations, 2018.
The changetoperformance category weights,theincreased performance threshold of 75 points, and changes in Quality and Cost reweighting create a big impact. On top of that, there are significant changes to Quality measures and bonus points that create a further challenge in scoring well.This is even true for clinicians with excellent Quality scores who are largely unaffected by the slew of changes to Quality measures that makes earning a high Quality score more difficult, as we have seen above in our example of how a primary care practice.
Impacts ofQuality Performance Category MeasureReporting Challenges on Specific Specialties
Some specialties are likely to experience more challenges in meeting the increased performance threshold. Consider the following radiology practice that reported six measures in 2018. The tables below illustrate the potential impact of changes between 2018 and 2022, primarily due to the proposed changes in scoring for the Quality performance category and the retiring and removal of highly topped-out Quality measures.
MIPS Category | 2018 Performance Category Points | 2018 Performance Category Weight | 2018 Composite Score |
Quality | 44/60 | 75% | 55 |
IA | 15/15 | 15% | 15 |
PI | 0/25 | 0% | |
Cost | 8/10 | 10% | 8 |
Total MIPS Score | 78 | ||
Penalty Threshold | 15 |
MIPS Category | 2022 Performance Category Points | 2022 Performance Category Weights | 2022 Composite Score |
Quality | 37/60 | 55% | 33.9 |
IA | 15/15 | 15% | 15 |
PI | 0/25 | 0% | |
Cost | 20/30 | 30% | 20 |
Total MIPS Score | 68.9 | ||
Penalty Threshold | 75 |
Like our primary care practice referenced above, the radiology practice is earning approximately the same performance category points in 2022 as 2018. (Cost is an exception to this, as the number of points in the Cost category changes with the number of applicable measures for a practice.The Quality score drops as well, which we will be explainedbelow, but the category weights also play a role.)However, the effect on the 2022 radiology practice’s final score is devastatingin a way not experienced by the primary care practice.Reporting the same categoriesthat earned 78% in 2018 earn only68.9% in 2022.To avoid a negative payment in 2022, this practice will need tobe exempted fromPIandsignificantly improve their Quality score.
But why did the practice’s Quality score drop so dramatically?Let’stake a closer look at what measures this practice reported to CMS in 2018 and whatmeasuresthey might report in 2022.
2018 Quality Composite Score | ||||
Measure # | Quality Performance | Measure AchievementPoints | Outcome/ High Priority Bonus Points | 2018 Total Points |
225 | 100% | 10 | 1 | 11 |
76 | 100% | 7 | 1 | 8 |
21 | 100% | 7 | 1 | 8 |
23 | 100% | 7 | 1 | 8 |
145 | 86.1% | 3 | 1 | 4 |
147 | 88.8% | 3 | 1 | 4 |
405 | 100% | 3 | 1 | 4 |
Total | 43 |
(In the table above, we’ve included all measures that earn points that contribute to the practice’s final Quality category score, whether those points are earned through measure achievement points or extra points from the outcome or high priority bonus points.)
2022 Quality Composite Score | ||||
Measure # | Quality Performance | Measure Achievement Points | Outcome/ High Priority Bonus Points | 2022 Total Points |
405 | 100 | 10 | 1 | 11 |
76 | 100% | 7 | 1 | 8 |
436 | 98.20% | 3 | 3 | |
145 | 86.1 | 2(or 1) | 1 | 3 |
147 | 88.8 | 2(or 1) | 1 | 3 |
406 | 100 | |||
Totals | 28 |
Our 2022 scenario has the radiology practice collecting data on the same available measures and achieving the same measure performance for all available measures as in 2018. However, the projected Quality points decrease by 16 points due to the removal of the three-point floor for measures with benchmarks (e.g. measures 145, 147), scoring 0 points for a measure without a benchmark (measure 406), and the removal of topped out measures on which the practice scored well (e.g., measures 21, 23, 195, and 225).While not factored in above, a practice could earn additional outcome/high priority or CERHT bonus points for measures reported beyond the top six. CMS has proposed to eliminate these bonus points as well. See a more complete explanation below:
2022 Proposed Changes to Quality Scoring
- Removal of the three-point floor for benchmarked measureswith an updated scoring range to 1-10 points.
- Reduced scoring for measures without benchmarksfrom 3 points to 0 points, even if the data completeness criteria are met.
- Removal of outcome/ high priority and CEHRT bonus pointsfor measures submitted beyond the top six.
Conclusion
We anticipate that the changes to MIPS requirements in the upcoming years will have a disproportionate effect on clinicians in non-patient-facing clinical settings, and specialty or clinical settings that are otherwise challenged with having few available Quality measures, measures without benchmarks, or topped out measures. A transition to MIPS Value Pathways (MVPs) or to QCDR measures may help these clinicians achieve more competitive MIPS scores. Regardless of specialty, it will be much more difficult for providers in any clinical setting to earn exceptional performance scores as they did in the early years of MIPS. The “easy-A” will be all but impossible to achieve. An attitude or strategy of “maintenance” will also not be enough to achieve outstanding performance, and for some practices, without significant effort or investment, will not be enough to avoid the payment adjustment. Whether your goal is to maximize your incentive, or simply to avoid the penalty, starting the reporting year without a solid plan to address these challenges will seriously cost you. MIPSpro and the Healthmonix team are here to help! Contact us today to start planning your strategy for MIPS success.
Topics: , Quality Performance Category, Cost Performance Category, 2022 PFS Proposed Rule
FAQs
What is the performance threshold for MIPS 2022? ›
How will CMS calculate your MIPS performance score in 2022 and 2024 payment adjustment? For the 2022 performance year, CMS set the performance threshold at 75 points. This is a significant increase from the 60-point threshold in the 2021 performance year.
What are the MIPS reporting requirements for 2022? ›- Merit-based Incentive Payment System (MIPS) Quality Measure Data. You must collect measure data for the 12-month performance period (January 1 - December 31, 2022). ...
- Electronic Health Record (EHR)-based Quality Reporting. ...
- Specialty Measure Sets. ...
- CMS Web Interface. ...
- CAHPS for MIPS Survey.
You need a score of at least 18.76 points to avoid the maximum –9% penalty (up from 15.01 points in 2021); there is a 75-point threshold to get a neutral adjustment (up from 60 points); and. there is an 89-point threshold for getting an exceptional performance bonus (up from 85 points).
What is the penalty for MIPS 2022? ›Also see MIPS 2020: A Primer and Reference, which is being posted online ahead of print. Harder to avoid the penalty. Your 2022 payments will be penalized if your 2020 MIPS final score falls below a performance threshold of 45 points (up from 30 points in 2019). Maximum penalty will be –9%.
What are MIPS performance categories? ›MIPS: One of Two Payment Tracks Under the Quality Payment Program (QPP) MIPS adjusts Medicare Part B payments based on performance in four performance categories: quality, cost, promoting interoperability, and improvement activities.
What happens if I don't participate in MIPS? ›What happens if I choose not to report any data to MIPS? Unless you qualify for an exemption from MIPS in 2022, you will receive a -9% payment adjustment to your Medicare Part B fee-for-service (FFS) claims in 2024.
What is exceptional performance bonus for 2022 MIPS? ›The additional performance threshold for exceptional performance for the 2022 MIPS payment year is 85 points. A MIPS eligible clinician with a Final Score of 85 points or higher will receive an additional payment adjustment factor for exceptional performance.
Why MIPS is not a good measure of performance? ›The above example demonstrates that MIPS is not always an appropriate performance mea- sure. The main reason for this is that MIPS does not take into account the complexity of the instructions, i.e, how much each instruction achieves towards the completion of a given task.
How much can MIPS adjust payments? ›The 2023 MIPS payment adjustments vary between -9% and +2.33%. For comparison, the 2021 MIPS payment adjustments vary between -9% and +1.87%.
What is a good MIPS score? ›For MIPS Score 89 – 100 Points: Budget-Neutral + Exceptional Performance Payment Adjustment The providers whose score lies in this range will not only earn the budget-neutral payment adjustment but will also earn an additional exceptional performance positive payment adjustment.
What is the MIPS penalty for 2023? ›
MIPS scores at or below 18.75 points would earn the full -9 percent penalty.
What is the minimum score for MIPS? ›For 2022, CMS set the performance threshold at 75 points. Physicians' MIPS scores are determined on their overall performance in each of the four MIPS categories compared to the CMS performance threshold score for a given year.
What's the downside to MIPS? ›MIPS scores may not accurately reflect care quality if providers are only reporting on performance measures that they see success with or are easy to achieve, some stakeholders noted.
Who is exempt from MIPS reporting? ›Who is exempt from MIPS based on the “Low Volume Threshold”? A. A clinician is exempt from MIPS under the Low Volume Threshold if they have fewer than or equal to $90,000 annual allowed Medicare Part B charges and/or see 200 or fewer unique Medicare Part B patients, and/or offer 200 or fewer Medicare services.
Should I participate in MIPS? ›You must participate in MIPS (unless otherwise exempt) if, in both 12-month segments of the MIPS Determination Period, you: Bill more than $90,000 for Part B covered professional services, and.
What are the four performance categories? ›Your performance is measured across 4 areas – quality, improvement activities, Promoting Interoperability, and cost.
How can I improve my MIPS score? ›Maximize score and positive adjustment: track your score at least quarterly and work to improve your score (and your positive adjustment). Prepare for APM participation & improve year-over-year performance: Alternative payment models typically have quality metrics and financial goals that you must make progress on.
Is MIPS only for Medicare patients? ›MIPS reporting of individual measures applies to all patients. Eligibility for a measure is based on CMS documentation (denominator criteria).
What is the penalty for not reporting MIPS? ›Avoiding a MIPS penalty can have a huge impact on your bottom line. Penalties for failing 2022 MIPS range up to 9% levied on your 2024 Part B professional service reimbursements.
Do hospitals report MIPS? ›In general, MIPS-eligible clinicians must select and report on six quality measures, but measure availability varies for patient-facing versus non-patient facing clinicians. Note that both categories include hospital-based clinicians.
How many improvement activities are required for MIPS? ›
To earn full credit in this performance category, you must generally submit one of the following combinations of activities: 2 High-weighted Activities, 1 high-weighted activity and 2 Medium-weighted Activities, or. 4 medium-weighted activities.
How much performance bonus is good? ›Performance Bonus
It is generally a percentage of your base salary (10-20% in most companies).
A performance-based bonus is an extra compensation granted to a team member as a reward for reaching pre-established goals and benchmarks. Leadership often rewards their teams with performance bonuses after evaluating outstanding projects or high-quality work performances.
What is a good performance bonus percentage? ›What is a good bonus? Generally, a “good” bonus would be anywhere between 10-15%. However, a bonus of 15% would likely be considered more than good, as it's one of the highest percentages and somewhat rare.
Is MIPS a good measure of performance? ›MIPS can be useful when comparing performance between processors made with similar architecture (e.g. Microchip branded microcontrollers), but they are difficult to compare between differing CPU architectures.
How do I reduce MIPS consumption? ›- Approach #1: Move Selected Workloads Off of the Mainframe. ...
- Approach #2: Deploy Alternative Technologies on the Mainframe. ...
- Approach #3: Migrate Away from the Mainframe. ...
- Ancillary Benefits.
This processor and its system-on-a-chip implementations are still popular and used in millions of devices (e.g. printers) even today. Since then, several improved variants of the original instruction set have been introduced: MIPS-I: the original 32-bit instruction set; still common.
Is it worth paying extra for MIPS? ›MIPS won't specify which brands or helmets are better at handling rotational impacts. All we know for certain is that a MIPS-equipped helmet is at least 10 per cent better at handling rotational forces than the same helmet without MIPS. Therefore, if there's a choice, go for MIPS.
Does MIPS really make a difference? ›MIPS' own testing shows that a helmet fitted with MIPS leads to a significant strain reduction compared to the same helmet without MIPS. MIPS measures the strain caused by an impact by using dummy heads that have the same kinematics as a human head and are fitted with six accelerometers.
How much difference does MIPS make? ›For MIPS, all they will say is any helmet equipped with MIPS is at least 10% better at handling rotational impact than the same helmet without MIPS. That's it. If the helmet only gets 9% better with the addition of slip plane technology, MIPS won't allow that helmet to get MIPS.
What is the data completeness threshold? ›
For MIPS, CMS has established a minimum threshold of data completeness. CMS expects those reporting within MIPS to meet this threshold and, thus, to have enough performance data for each measure to be objectively and fairly scored. The current MIPS data completeness threshold is 70%.
How do you explain MIPS? ›The Merit-Based Incentive Payment System (MIPS) is the program that will determine Medicare payment adjustments. Using a composite performance score, eligible clinicians (ECs) may receive a payment bonus, a payment penalty or no payment adjustment.
Is MIPS required for 2023? ›You must collect measure data for the 12-month performance period (January 1 - December 31, 2023). There are 5 collection types for MIPS quality measures: Electronic Clinical Quality Measures (eCQMs); MIPS Clinical Quality Measures (CQMs);
Is late enrollment penalty forever? ›Generally, the late enrollment penalty is added to the person's monthly Part D premium for as long as they have Medicare drug coverage, even if the person changes their Medicare plan. This also means that if a person joins a plan that has a $0 monthly premium, they'll still owe a penalty.
What are MIPS improvement activities 2023? ›The MIPS Improvement Activities performance category rewards eligible clinicians (ECs) and groups for engaging in clinical practice improvement activities such as care coordination, beneficiary engagement, and patient safety. Improvement Activities account for 15% of the total MIPS score in performance year 2023.
What is the range of MIPS scores? ›Your performance across the MIPS performance categories, each with a specific weight, will result in a MIPS final score of 0 to 100 points. Your MIPS final score will determine whether you receive a negative, neutral, or positive MIPS payment adjustment.
Can MIPS be removed? ›Warning: the Mips system in a helmet has been positioned in accordance with specifications for that particular model of helmet. Users are warned not to remove, reposition or otherwise tamper with the Mips system in the helmet.
Is MIPS really safer? ›Better Safety
It's a no-brainer that helmets infused with MIPS offer improved safety and protection compared to regular non-MIPS helmets. The research studies we mentioned above also suggest the same thing. MIPS Company, on the other hand, claims that it can reduce the rotational force impact by about 10%.
A Mips or Multi-directional Impact Protection System is a low-friction layer located between the EPS and inner helmet liner that reduces rotational impact forces. This helps protect your brain from concussion and trauma.
Do you have to report MIPS as a group? ›If you're MIPS eligible at the group level only, your practice can participate in MIPS as a group but is not required to do so. If your practice chooses to participate as a group, the MIPS eligible clinicians who aren't eligible as individuals will be included in MIPS and receive a payment adjustment.
What are MIPS requirements? ›
You have to attest that you completed, for a minimum of 90 days, one or more Improvement Activities. You can earn a maximum of 40 points for this category (carries 15% weight towards the final MIPS score). Improvement Activities are divided into medium-weight and high-weight activities.
What is the deadline for MIPS reporting? ›The Centers for Medicare & Medicaid Services (CMS) has opened the performance year 2022 data submission period for the Merit-based Incentive Payment System (MIPS). MIPS-eligible clinicians who participated in the Quality Payment Program (QPP) in 2022 can submit and update data until 8 p.m. ET on March 31.
What are the benefits of MIPS? ›According to HHS, “MIPS was designed to tie payments to quality and cost-efficient care, drive improvement in care processes and health outcomes, increase the use of healthcare information, and reduce the cost of care.”
What is the MIPS performance threshold? ›MIPS participants who exceed the separate exceptional performance threshold, which has been set at 89 points for 2022, are eligible for an additional positive payment adjustment from a separate pool of funding.
What is the performance period for MIPS? ›When. The MIPS performance year begins on January 1 and ends on December 31 each year. If you're eligible for MIPS, you must report data collected during the calendar year by March 31 of the following calendar year.
What is the low volume threshold for MIPS? ›Who is exempt from MIPS based on the “Low Volume Threshold”? A. A clinician is exempt from MIPS under the Low Volume Threshold if they have fewer than or equal to $90,000 annual allowed Medicare Part B charges and/or see 200 or fewer unique Medicare Part B patients, and/or offer 200 or fewer Medicare services.
What score do you need on MIPS? ›Quality Scoring (30% of score or up to 30 points toward MIPS score): Data Completeness Requirements: Minimum 70% data completeness is required to achieve the maximum points for each measure.
How do I increase my MIPS score? ›Create opportunities to assess total cost of care and identify ways to reduce unnecessary costs. Enhance the measurement of the quality of care, making quality data relevant at practice and panel levels, and use those data to implement effective quality improvement activities.
What is the proposed rule for MIPS 2023? ›The rule provides policy updates to the traditional Merit-based Incentive Payment System (MIPS) program, the new MIPS Values Pathway (MVPs) framework, Alternative Payment Models (APMs), and Accountable Care Organizations (ACOs).
What are the disadvantages of MIPS? ›MIPS scores may not accurately reflect care quality if providers are only reporting on performance measures that they see success with or are easy to achieve, some stakeholders noted. Provider groups also told GAO that some quality measures assess activities that are not common for all specialties.
What is a MIPS score of 45? ›
A score of 45 qualifies for MIPS standards under medium weight verification. These rules apply for any institution, group, or individual. Bonus points earned for a MIPS category are dependent on CMS review via the QPP laws for bonus points. Scores in the 45 to 85 range will receive up to 9% billing change.
What are the 3 MIPS instruction types? ›There are three instruction categories: I-format, J-format, and R-format (most common).