The MIPS program has entered its 6^th year, and the 2022 program final rule has outlined the performance thresholds and reporting requirements. The minimum performance threshold is set at 75 points.  That’s a steep increase from the 3 points required in 2017 when the program started.    Eligible clinicians will incur a 9% penalty deduction for being non-compliant this year.

The most challenging year for MIPS has begun and clinicians need to strategize on how to maximize program compliance.  We’ll break down the changes made to each MIPS category, so you can meet program performance thresholds and develop a MIPS strategy to optimize your MIPS score.

Quality Category

The weightage for the Quality category is set at 30%. The Quality category must be reported for the whole year. Clinicians must report a minimum of six Quality measures, with one of those measures being an Outcome measure.  More than six measures can be reported for the Quality category, but the CMS only scores the six best measures when this happens.

Quality measures can earn a score between 0-10 points.  If you are a small practice made up of 15 or fewer clinicians you will earn a minimum of 3 points for each Quality measure you report even if it doesn’t meet data completeness requirements.  Attaining 10 points on each of the six measures reported, a clinician receives a Quality score of 60 points.  This doesn’t mean that you receive 60 points for your overall MIPS score.  The maximum points you can receive for Quality is 30 points.

Data completeness threshold remains at 70%.  Eligible clinicians must report at least 70% of their patient population for a quality measure.  For example, if 1000 patients are applicable to be reported for a quality measure, an eligible clinician must report the measure on a minimum of 700 patients to meet data completeness.  A Quality measure must be applicable to a minimum of 20 patients for it to qualify for data completeness.  Failure to meet data completeness will result in a 0 score (3 for small practices) for a measure.

The Quality category remains the highest weighted category for MIPS.  Clinicians must report measures that meet data completeness requirements and earn them an exceptional score.  Substandard Quality performance is very risky this year. Clinicians must make the most of their Quality score to avoid a penalty deduction.

Promoting Interoperability Category

The weightage for the Promoting Interoperability Category is set at 25%.  This category must be reported for a minimum of 90 days.    The following PI measures must be reported by a clinician for MIPS this year.

• e-Prescribing
• Provide Patients Electronic Access to Their Health Information
• Support Electronic Referral Loops by Sending Health Information
• Support Electronic Referral Loops by Receiving and Reconciling Health Information
• Health Information Exchange (HIE) Bi-Directional Exchange (If this measure is reported you don’t have to report both of the Support Electronic Referral loops measures mentioned above).
• Electronic Case Reporting
• Immunization Registry Reporting, Syndromic Surveillance Reporting, Public Health Registry Reporting, and Clinical Data Registry Reporting (Must report one of these four measures).

If any of these measures are not reported and an exclusion has not been applied, the whole PI category receives a score of 0.  Previously, if any of these measures were not reported, you would lose out on the points for the specific measure not reported.  If you run into a measure you cannot report, you must thoroughly review the applicable exclusion criteria and apply an exclusion for that measure to save your points.   Clinicians cannot afford to lose 25 points this year by reporting PI like they did in previous years.  Every point matters this year and it can make or break your score.

Improvement Activities Category

The weightage for this category is 15%.  The category must be reported for a minimum of 90 days.   Improvement activities are either weighted as medium-weighted or high-weighted.  If you are a small practice you need to report either two medium-weighted activities or one high-weighted activity to ensure 100% compliance for this category.  A large practice needs to report four medium-weighted activities or two high-weighted activities to be 100% compliant.

This category is the easiest category to yield 100% compliance, but clinicians must review the data validation criteria of each Improvement Activity they report to make sure they are reporting the activity correctly.

Complex Patient Bonus

The complex patient bonus is capped at 10 points.  These points are added to a clinician’s score after final data submission.  Clinicians that have a median or greater value for at least one of two risk indicators (Hierarchical Condition Category (HCC) and proportion of patients both eligible for Medicaid and Medicare benefits) are eligible to receive these bonus points.

Cost Category

The weightage for this category is 30%.  This category requires no data submission.  The CMS scores this category based on a clinician’s Medicare Part A and B claims submitted throughout the year.  It compares the cost of care provided by a clinician to a national benchmark.

If a clinician scores 100% compliance for the Quality, Promoting Interoperability, and Improvement Activities categories and receives an additional 5 bonus points that will yield a score of 75 points.  With a score of 75 points, the clinician will have successfully avoided the penalty deduction.  This is without the 30 points of the Cost category being calculated and added to the clinician’s score.

If you want to learn more about being 100% compliant for the Quality, Promoting Interoperability, and Improvement Activities categories please contact us at 717-680 8500 or email qp@curemd.com