As the Merit-Based Incentive Payment System (MIPS) approaches its sixth year, the providers should prepare to participate (or begin) in the program. Failure to participate in the program in 2022 or achieve specified program requirements may result in a -9 percent payment adjustment for eligible professional services reimbursed under or based on the Medicare Physician Fee Schedule. The maximum payment adjustments for 2022 will be applied to a clinician’s Medicare Part B reimbursements for eligible professional services in 2024 and will stay at +/- 9%.
To be eligible for an incentive payment in 2022, providers must additionally earn a score of 75 points, up from 60 points in 2021. An additional performance threshold of 89 points has been introduced for excellent achievement. The extra MIPS compensation for excellent performance will be released after the 2022 performance year.
Individual MIPS-qualifying doctors, groups, and virtual groups reporting traditional MIPS will have their performance categories weighted as follows. These figures indicate minor adjustments from 2021 (as mentioned below):
- Quality = 30% (down from 40% in 2021)
- Cost = 30% (up from 20% in 2021)
- Promoting Interoperability = 25%
- Improvement Activities = 15%
Providers who wish to participate in the 2022 MIPS program through Qualified Clinical Data Registries (QCDRs) or Qualified Registries can now access a list of registries certified by CMS to collect and report clinical data to the MIPS program on their behalf.
- 2022 Qualified Registries Qualified Posting
- 2022 QCDRs Qualified Posting
By visiting CMS’s Quality Payment Program Participation Status page, providers can check their eligibility for MIPS in 2022 or earlier years.
In response to the COVID-19 Public Health Emergency, CMS is implementing an Automatic Extreme and Uncontrollable Circumstances (EUC) Policy for the 2021 MIPS Performance Year (PHE). Depending on how providers report MIPS, the regulation affects them differently. The automatic EUC policy, for example, applies solely to MIPS-qualified doctors who engage in MIPS as individuals, not to groups, virtual groups, or Alternative Payment Model (APM) Entities.
However, because reporting beyond the individual level is often voluntary if groups and APM organizations cannot provide MIPS data for 2021, individually qualified MIPS physicians in such groups and APM entities will still qualify for the automatic EUC policy. On the other hand, virtual organizations and certain small practices operate under separate rules, and their members may not benefit from the automatic policy. However, 2021 EUC Exception Applications can still be filed until December 31, 2021, by logging in to qpp.cms.gov and selecting Exception Applications from the left-hand menu.
Other key MIPS dates and deadlines to keep in mind as we wrap up 2021 and begin 2022:
December 31, 2021 – To receive approval to participate as a virtual group for the 2022 performance year, groups must submit an election to CMS via e-mail (MIPS_VirtualGroups@cms.hhs.gov) by 11:59 p.m. ET.
January 1, 2022 – The payment adjustments based on the performance year 2020 go into effect, and the 2022 performance year begins.
January 3, 2022 – 2021 MIPS performance year data submission window opens.
March 31, 2022 – 2021 MIPS performance year data submission window closes.