CMS Requirements for MIPS 2022 – What’s at Stake?

Written by Sarah Reiter, SVP Strategic Partnerships with Health eFilings

On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) issued the Final Rule for the 2022 MIPS program.  These rules detail the requirements for this MIPS reporting period, which started on Jan. 1, 2022, and align with CMS’ overarching MIPS program goals to incent the use of technology and encourage clinicians to focus on areas that improve quality and reduce cost.

Overall, the MIPS program is more complex than past years and, by law, structured such that 1 out of every 2 clinicians will be penalized starting in 2022 with a penalty of up to 9%.   Many elements from 2021 remain including the data completeness requirements to submit a full year’s data for all patients, all payers; and stringent timeline requirements for Promoting Interoperability (PI) and Improvement Activities (IA) categories.  Its critical to also be aware and understand the implications of this year’s changes as failure to comply or earn enough MIPS points will result in an automatic penalty.  Several of the key take-aways include:

You must earn at least 75 out of the possible 100 MIPS points to avoid the 9% penalty

The increase of the threshold to avoid penalty from 60 in 2021 to 75 points in 2022 represents the 5th straight year of threshold increases.  This increase is intentional to meet the requirements of the law stating the threshold must be set at the median in 2022, meaning 50% of all clinicians will be penalized.  There will be more clinicians penalized than ever before and earning positive payment adjustments will be harder than ever.

Significant changes to quality measures

To achieve CMS’s goals through the MIPS program, they actively change and update measure definitions, often at various times throughout the year and with no published notice.  To kick off 2022, there are changes to many quality measures, meaning it may not be in your best interest to focus on measures used in the past and measures used in the past may or may not still exist.

Improvement Activities category is more relevant than ever before

Because of the 75-point threshold to avoid a penalty, clinicians must maximize MIPS points in every category, including Improvement Activities.  There are newly added activities this year but the biggest change in the category is now reweighted points are equally distributed between the Quality and Improvement Activities categories.  It’s more important than ever to have a strategy and begin executing it now to meet the requirements and minimum time-period.

New clinician types eligible (aka required) to comply with MIPS

Clinical Social Workers and Certified Mid-wives are now eligible clinician types and must catch up to meet the requirements of participation.

Within this framework, it is still challenging to know how to earn MIPS points, optimize your score and protect your reimbursements given the nuances and commonly misunderstood aspects within the MIPS program.   The one thing you can control is the MIPS reporting partner and corresponding reporting method you choose.  Given what’s at stake and the complexity in earning MIPS points, selecting a MIPS expert who can guide you and optimize MIPS points is critical. In fact, hiring an expert is the most strategic decision you can make to determine which side of the penalty line you fall and what impact that makes on Medicare reimbursements. Remember, not all reporting options are the same.

Health eFilings, a CEHRT and the national leader in automated MIPS reporting, is the most comprehensive and effective choice for MIPS reporting. We use a cloud-based, ONC-certified software that fully automates the process and does all the work without requiring IT resources, administrative support or workflow changes.  Health eFilings will save significant time, be a turnkey submission process and maximize the financial upside by earning the most MIPS points.  And you can have peace of mind because Health eFilings has a 100% success rate with CMS accepting our electronic submissions on behalf of our clients.  With what’s at stake this year and beyond, you can’t afford to make mistakes with MIPS.

And, finally – if you haven’t filed for 2021, don’t accept the automatic 9% penalty for non-compliance as Health eFilings can still assist.  But time is of the essence, reach out now to get started.