2022 QPP Proposed Rule

CMS recently published the CY 2022 Quality Payment Program (QPP) proposed rules which include many changes to the Merit Based Incentive Payment System (MIPS) for 2022 and subsequent reporting years. The full text of the rule can be viewed on the Federal Register.

Transition from MIPS to MVPs

Clinicians and third-party intermediaries will be given until the 2023 MIPS performance year to begin their transition to MIPS Value Pathways (MVPs) and prepare for the sunset of MIPS, which is planned for the end of 2027. This transition to MVPs will better align the activities and measures from the four MIPS performance categories (Quality, Promoting Interoperability, Improvement Activities and Cost) with specialty care, medical conditions, and episodes of care. The Promoting Interoperability performance category and population health claims-based measures will be the foundational elements of the MVPs. MVP Participants will need to register for the MVP and as a subgroup if applicable. The registration process will be between April 1st and November 30th of the performance year. However, to report CAHPS for the MIPS Survey associated with an MVP, the proposal by CMS is for a group, subgroup, or an APM entity to complete their MVP registration by June 30th of the performance year. For details about the proposed, specific registration requirements, please review the QPP Proposals Overview on the QPP website Resource Library.

Note: CMS is also setting a high priority on digital quality measurement (DQMs) and the focus is on health equity.  The plan is for all Quality Reporting and Value-Based Purchasing programs to be fully digital by 2025.

CMS plans to align the future MVPs with broader initiatives such as the CMS Quality Measure Action Plan which will adopt measures that are the most critical to providing high quality care within the quality programs.  The goals are to:

• Transform activities of quality measurement and value-based programs
• Align measures and reduce quality measure reporting burdens
• Identify activities that drive better outcomes at lower costs

 Proposed MVP Changes

The MVP reporting requirements for all MVP participants (individual eligible clinicians, groups, subgroups, and APM Entities) and category weighting will be consistent with traditional MIPS policies, but with a few exceptions.

For Population Health measures, when MVP participants initially register, they will select 1 population health measure to be calculated on. The results will be added to the quality score. It is proposed that for the 2023 performance year, the two population health measures available for selection will be the Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) and the Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions. The Population Health scoring exception is for subgroups, and they will receive the score of their affiliated group.

For the Promoting Interoperability performance category, MVP participants will report on the same Promoting Interoperability measures required under traditional MIPS, unless they qualify for automatic reweighting or have an approved hardship exception. The traditional MIPS performance weight for this category will remain the same at 25%. There is no scoring exception for this category.

For the Quality Performance category, MVP participants will select the four quality measures available. One measure must be an outcome measure (or a high-priority measure if an outcome measure isn’t available or applicable). This can include an outcome measure calculated by CMS through administrative claims, if available in the MVP. The traditional MIPS performance weight for the Quality Performance category will change from 40% to 30% in 2022. The scoring exception for this category applies to small practices. They will continue to earn 3 points for these measures.

The Improvement Activities performance category, all MVP participants will select two medium-weighted improvement activities OR one high-weighted improvement activity OR IA_PCMH, if available in the MVP. The traditional MIPS performance weight for this category remains the same at 15% and there are no scoring exceptions.

For the Cost Performance category, CMS will calculate performance exclusively on the cost measures that are included in the MVP using administrative claims data. (Remember - MVP participants will not submit data on cost measures). The traditional MIPS performance weight for the Cost category will increase from 20% to 30% and there are no scoring exceptions.

Note: Scoring for MVPs will align with those used in traditional MIPS across all performance categories, with the few exceptions mentioned above.

Collection Types

The four available collection types for groups and virtual groups are proposed to remain unchanged and CMS is proposing to extend the sunsetting the CMS Web Interface collection type through the 2022 performance period for registered groups, virtual groups and APM entities with >25 clinicians.

• Electronic Clinical Quality Measures (eCQMs)
• Medicare Part B Claims Measures
• MIPS Clinical Quality Measures (MIPS CQMs)
• QCDR Measures

Note: CMS is also proposing to establish subgroup reporting to provide patients and clinicians with information that is clinically meaningful at a more granular level. Transitioning to subgroup reporting, will be voluntary for the 2023 and 2024 performance years.

Quality Measures

There are substantial changes proposed to 84 of the existing MIPS quality measures. With the proposed changes to specialty sets, the removal of measures from specific specialty sets, the removal of 19 quality measures and the addition of five quality measures (two being administrative claims measures) the total number of quality measures available for the 2022 performance period will decrease by 11 (dropping from 206 to 195).

Pending the analysis of the 2020 performance period data, CMS may propose changes to the Quality Measure Benchmarks baseline. However, they do propose to keep the threshold for data completeness at 70% for 2022 but plan to increase it to 80% for the 2023 performance period. There are proposed changes planned for the quality measure scoring for new measures, measures with and without a benchmark, measures that don’t meet case minimum and CMS proposes to remove the high-priority bonus points for reporting additional outcome and high priority measures in the 2022 performance period.

For the MIPS Cost Performance category, CMS is proposing to add five new episode-based measures. There is also a proposal to suspend the Improvement Activities when there is concern for patient safety if data collection is continued or if it is obsolete. There are also changes proposed to the criteria for nominating a new Improvement Activity.

For the Promoting Interoperability performance category, CMS is proposing to apply automatic reweighting to two clinician types (Clinical Social Workers and Small Practices). If the proposed rules become final, MIPS eligible clinicians will be required to submit data to the Immunization Registry and to the Electronic Case Registry unless an exclusion can be claimed. Regarding EHRs, there are also changes proposed that will affect a patient’s Electronic Access to their health information, Information Blocking and with EHR Safety Assurance Factors.

There are also several change proposals that will affect the redistribution of the performance category weights for small practices, payment adjustments for the Performance Threshold/Additional Performance Threshold and Incentive Payments for Advanced APM Qualified Participants.

Medicare Shared Savings Program

With the transition to reporting all payer quality data for the eCQM/MIPS CQM quality measures, CMS is proposing to extend the CMS Web Interface as an option for two years for ACOs. Along with the extension, CMS is proposing a one-year freeze on the phase-in of the increased number of quality performance standards that ACO must meet. The proposal to extend the reporting requirements for the submission of all-payer quality data, under the APP would give clinicians and facilities more time to prepare.

For the 2022 performance year, ACOs would either report the 10 CMS Web Interface measures or the 3 eCQMs/MIPS CQMs. Under the APP, all ACOs would administer the CAHPS for MIPS Survey and be scored on two administrative claims-based measures (calculated by CMS).

For performance year 2023, ACOs would either report the 10 CMS Web Interface measures and at least one eCQM/MIPS CQM or the 3 eCQMs/MIPS CQMs. Under the APP, all ACOs would continue to administer the CAHPS for MIPS Survey and be scored on two administrative claims-based measures (calculated by CMS).

Please see the QPP Proposed Policy Changes for 2022 for details on all of the proposed changes for 2022 and subsequent years.

CMS wants your feedback on the 2022 QPP proposed policies and rules. The 60-day comment period has begun and will end on September 13th, 2021. You may use any of the following options to officially submit your comments:

• Electronically through regulations.gov
• Regular mail
• Express or overnight mail
• Hand or courier

If you have questions about MIPS/MVPs reporting, please contact us.