Changes in the Reporting Requirements
The reporting requirements were established in the first year of the Centers for Medicare and Medicaid (CMS)’s Quality Payment Program (QPP). The framework that is currently available to the MIPS eligible providers is the Traditional MIPS framework it was also the initial one. It is eligible for the providers to obtain and report performance data measures across the following areas:
- Promoting Interoperability (PI)
- Improvement Activities
Until they choose or are obliged to utilize the new APP (which will be available in 2022) or the new MVP framework, only MIPS-eligible doctors may use the existing MIPS framework (which will be available at the beginning of the year 2023).
General Changes That Occur In MIPS—2022
In 2022 two new types of providers are considered for the MIPS – 2022 eligible clinicians:
- Certified nurse-midwives
- Clinical social workers
What’s The Importance of This?
- These additions were proposed by the CMS to align with the definition of the Alternative Payment Model (APM)’s eligible clinicians.
Who is an Eligible Clinician (EC)?
An eligible clinician (EC), such as an APM participant, is a healthcare professional who is qualified to take part in the QPP MIPS and other CMS programs by employing the electronic clinical quality measures (eCQMs) for the repowering.
In order to gather the MIPS-required data components, new provider workflows must be built for all of your practice’s providers, including licensed midwives and social workers.
Clinical Social Workers Under MIPS Considerations
However, Clinical Social workers are not allowed to report on MIPS in the year 2020 and 2021 but then CMS introduces a finalized Clinical Social Work MIPS specialty measure set and allow them to participate in MIPS reporting in the year 2022 now they are eligible for the performance year 2022.
In the Social Work, MIPS Specialty Measure Set What Are The Quality Measures?
Early in the year 2022, CMS anticipates completing the approved Quality Measures for the Social Work Specialty Measure Set. The approved 2022 quality measures may marginally diverge from the 2021 quality measures that were finally finalized.
The final Quality Measure Set for 2021 is listed below:
- In the Medical Record Documentation of the Current Medication
- Screening and Prevention Care: Usage of Tobacco: Cessation Intervention and Screening
A few Quality Measures That Are More Specific To The Social Work Specialty, Here Are The Following:
- Preventative Care and Screening: Depression Screening & Follow-Up plan.
- Elder Maltreatment Screening and Follow-Up
- Cognitive Assessment of Dementia
- Functional Status Assessment: Dementia
- Education and Support of Caregivers for patients having Dementia
- Depression Remission
Promoting Interoperability MIPS Requirements and Clinical Social Workers
As mentioned above to fulfill the MIPS there are four different categories in which one of them is Promoting Interoperability (PI). It is stated by the CMS that clinical social workers may automatically reweight their PI score to zero and distribute their total MIPS scoring per the following:
- Quality Increases from 30% to 40%
- Cost Remains at 30%
- Improvement Activities Increases from 15% to 30%
Automatic Reweighing has been provided for clinicians who belong to small practices such as those with 15 or fewer MIPS – eligible clinicians who bill under the practice’s Tax ID Number (TIN)
Certified Nurse Midwives under MIPS Considerations
Qualified Nurse Midwives (CNMs) are Advanced Practice Registered Nurses (APRNs) who are also certified as midwives (CNMs). Because they are APRNs and have greater clinical responsibilities than registered nurses, they are qualified to prescribe drugs (RN).
Currently, CMS does not offer Certified Nurse Midwives a Clinical Quality Measure Set. They must submit separate reports for six Quality Measures, after all.
Overall Changes in MIPS Scoring
Changes in Reporting: Beginning with the Performance Period 2022, the QPP program is required by law to weigh Quality and Cost categories at 30%. Well, the Promoting Interoperability (PI) and Improvement Activities (IA) categories percentages remain the same as same in the year 2021: 25% and 15% respectively. (As stated above, an exception is made only to the small practices and clinical social workers whose PI categories are weighted to zero).
Performance Thresholds: At the beginning of the year 2022, ECS much reach a Minimum Performance Threshold of the total MIPS of 75 points – up from 60 points in the year 2021.
A score of 75 points was the final score in the 2017 Performance Period. This fulfills the CMS requirements. However, in 2022 eligible clinicians must establish a performance threshold that is medium or mean of all eligible clinicians for a final score for an earlier PP.
Moreover, to receive the exceptional performance bonus for the 2022 performance, MIPS-eligible clinicians need to receive a score of >89 points. Well, 2022 is the last year for the participating providers to receive an exceptional performance bonus.
At the start of 2023, just the penalty fee will fund the program. As the requirements of the program fund become more difficult. Well, it is expected that more eligible clinicians get affected by the negative payments.
Improvement Activities Category (IA)
In the performance year 2022, CMS is retaining
- The same weight for IA performance score at 15% of the total MIPS score
- Selection of medium and high-weighted activities to fulfill the IA score
- Performance Period for a minimum of 90 days
Modified, New, and Retired Improvement Activities for CY 2022
- Seven new IA’s added by CMS which also includes three new health equity measures
- 15 IA’s modified by CMS of which 11 of them are health equity measures
- Six previous IA’s removed by CMS
Cost Category in 2022
CMS has used cost measures for the year 2021 are following:
- Total per capita cost (TPCC) given to Medicare patients while focusing on the primary care
- Medicare spending per beneficiary clinician
- The cost of items and services provided during the 18 episodes of care of Medicare patients
Quality category in 2022
To be consistent with its plans for scoring the new MIPS Value Pathways, CMS is proposing a number of adjustments to the standard MIPS Quality Measure Scoring at the start of 2022. (MVPS). At the beginning of the 2023 performance year, CMS will introduce the MVPS gradually to provide clinicians, HER vendors, payers, and other third parties sufficient time to prepare.
CMS Used A Different Baseline Period Due To Covid-19
The complete calendar year will once again serve as the Quality reporting period in 2022. However, CMS is recommending the use of a different baseline period as performance period standards, such as the calendar year 2019, pending evaluation of the 2020 PP data, due to the uncontrolled and extraordinary circumstances resulting from the COVID-19 public health emergency (PHE).
Scoring Updates To The Quality Performance Category
In the year 2022, there are several scoring changes occurred in the Quality Category:
- New Quality Measures
- Quality measure case and minimum requirements
- Quality measure data completeness requirements
Promoting Interoperability Category
For the performance year 2022, there are new reporting requirements for Traditional MIPS.
- Public health and clinical data exchange
There are some significant changes in the existing MIPS 2022. In preparation for CMS to move forward, two new pathways programs will replace the traditional MIPS. In this reading, you will get familiar with the changes that occurred in the traditional MIPS 2022.