QPP: 2022 CMS Proposed Rule

CMS 2022
PROPOSED RULE
QUALITY PAYMENT PROGRAM

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MIPS 2022
KEY THINGS TO KNOW

REMEMBER
Remember, these proposed
changes are not finalized yet.

The Start of the MVPs Program
• CMS is phasing in the MIPS Value
Pathways (MVPs) program starting
in 2023.

There are 7 initial MVPs and participants
must register for the MVP between April 1
and November 30 of the performance year.
1. Rheumatology
2. Stroke Care & Prevention
3. Heart Disease
4. Chronic Disease Management
5. Emerging Medicine
6. Lower Extremity Joint Repair
7. Anesthesia

MVP works similarly to the traditional MIPS
program, but it gives you specific measures
according to the MVP you are in.
• Quality category: Select 4 measures, one must be
an outcome measure.
• Improvement Activities: Select 2 medium-weight
or 1 high-weight measure(s).
• Promoting Interoperability: Report on the same
PI measures required under traditional MIPS.
• Cost: Calculated exclusively on the cost measures
that are included in the MVP using administrative
claims data.
• New Foundational Layer (MVP agnostic): Report
1 (of 2) new Population Health measures, which is
added to your Quality score.
MVP Reporting Requirements

APP Reporting Option
• CMS is proposing a new APM
Performance Pathway (APP) reporting
option available in 2022.
• Quality measures reported through the
APP are automatically used for the
Medicare Shared Savings Program
quality scoring, satisfying the
requirements for both programs.

Increasing
Performance
Threshold
T W O

Increasing Performance Threshold
The performance threshold
will increase from:
50 points to 75 points
This is based on the mean average from
previous years. Eligible Clinicians need to score
at least 75 points to avoid a penalty in 2022.

Increasing Performance Threshold
Also, you must score a minimum of
89 points
To receive the Exceptional Performance bonus
money. This is the last year to receive an
exceptional performance bonus payment.

Minimum Score by Year

2021 Performance
Threshold
85
PTS.
0%
50
PTS.
0
PTS.
100
PTS.
$$$$$$$$$$$$$$$$$$$$$$$$$$$$$
$$$$$$$$$$$$$$$$$$$$$$$$$

2022 Performance
Threshold
89
PTS.
0%
75
PTS.
0
PTS.
100
PTS.
$$$$$$$$$$$$$$$$$$$$$$$$$$$$$
$$$$$$$$$$$$$$$$$$$$$$$$$

Penalties & Incentives

What can you lose, what can you gain?
-9%-0%
For not meeting the minimum score (75)
<9%
For the top performers (89)

Revising
Category
Weights
T H R E E

The
category
weights
have been
modified.

Traditional MIPS
Quality:
40%
Cost:
20%
PI:
25%
IA:
15%
Quality:
30%
Cost:
30%
PI:
25%
IA:
15%
2021 2022

2022 Weights
Quality:
40%
Cost:
20%
PI:
25%
IA:
15%
Traditional MIPS
Quality:
50%
PI:
30%
IA:
20%
Quality:
55%
PI:
30%
IA:
15%
Traditional MIPS
for APM Entities APP Reporting

Modifications
to the
Category
Requirements
F O U R

2022 Quality Category
Category weight:
30%
Performance Period:
365 days
%

CMS will allow
the CMS Web
Interface
Submission
Option
in 2022 & 2023
BUT

Starting in 2023
MSSP ACOs can
still submit the
CMS Web Interface
Measures but they
MUST submit 1
eCQM/CQM in
2023.

Starting in 2023
CMS Web Interface
will no longer be
available to all
other APM Entities.
They MUST submit
eCQMs or CQMs in
2023.

Quality Category Changes
• Removing 19 quality measures
• Significantly change 84 existing MIPS quality measures
• Add 5 new quality measures (2 of which are administrative
claims measures)
• Risk-standardized acute unplanned cardiovascular-related
admission rates for patients with heart failure for MIPS.
• 21-case minimum, 1 year performance period, applies to MIPS
Eligible Clinicians, Groups and Virtual Groups.
• Clinician and Clinician Group risk-standardized hospital
admission rates for patients with multiple chronic conditions.
• 18-case minimum, 1 year performance period, applies to MIPS
Groups with at least 16 Eligible Clinicians.
Measure Adjustments

• CMS is proposing to move the data
completeness threshold from 70%
(current state) to 80% starting in 2023.
Data Completeness

• In the past, CMS has put a 3-point floor
on scoring for all quality measures.
This floor is eliminated. You can now
score between 1-10 points.
• However, new quality measures, in their
first performance period, will have a 5-
point floor.
Scoring

• CMS is proposing to remove the bonus
points for:
• Reporting an additional outcome or high-
priority measure
• Reporting using end-to-end electronic
reporting
Scoring

2022 Cost Category
Category weight:
30%
Performance Period:
365 days
%

Like 2021, CMS will
use these measures
for Cost:
• Total Per Capita Cost
(TPCC)
• Medicare Spending Per
Beneficiary (MSPB)
• 18 episode-based
measures

In 2022:
• 5 new episode-based
measures
• 2 procedural measures
• 1 acute inpatient measure:
sepsis
• 2 chronic condition
measures: Diabetes and
Asthma/COPD

2022 Improvement Activities Category
Category weight:
15%
Performance Period:
90 days
%

CMS is proposing
some measure
changes in this
category:
• Add 7 new Improvement
Activities (IA) measures, 3
of which are related to
promoting health equity
• Modify 15 IA measures
• Remove 6 IA measures

2022 Promoting Interoperability Category
Category weight:
25%
Performance Period:
90 days
%

PI Category Changes
• In the past, you could choose which
two public health and clinical data
exchange measures to submit (from a
list of 5), CMS proposes to require you
to submit these two measures:
1. Immunization Registry Reporting
2. Electronic Case Reporting
Measures

PI Category Changes
• CMS wants to modify the Providing Patient
Electronic Access measure to require patient
health information to remain available to the
patient indefinitely.
Measures

PI Category Changes
• CMS is proposing a new measure in this
category. Eligible Clinicians must attest to
conducting an annual assessment of the
High-Priority Guide of the SAFER Guides.
• Safety Assurance Factors for EHR
Resilience (SAFER) Guide.
Measures

PI Category Changes
• CMS is modifying the Prevention of
Information Blocking Attestation
Statements and
• Modifying the Complex Patient Bonus
in 2022.
Measures

PI Category Changes
• For some Eligible Clinicians, CMS
automatically reweights this category to
0 points and adds that percentage weight
to their quality score.
• CMS proposes to include Clinical Social
Workers and Small Practices to the list of
Eligible Clinicians whose score will be
automatically reweighted.
Scoring

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QPP: 2022 CMS Proposed Rule

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