Final 2022 MIPS Rule Changes and Eight Important Lessons for Pathology Practices

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For reaching threshold levels of payments and patients, participants who meet the requirements to be considered Advanced APM participants are given a 5% reward. Every other qualified clinician is required to take part in MIPS. Participants in MIPS receive a positive or negative payment adjustment depending on how well they performed in the relevant weighted performance areas.

The focus of this essay will be on changes that will affect MIPS because there are no 2022 APM-related changes that will affect single-specialty, non-patient-facing pathology groups.

75 as the new performance threshold

From 60 points in 2021 to 75 points in 2022, the performance threshold rose. Participants who get fewer than 75 points in 2022 will be subject to a negative payment adjustment of up to 9% in 2024. Participants who earn more than 75 points will have their payments adjusted in their favor. Additionally, CMS raised the outstanding Performance Threshold from 85 to 89 points in 2022. The final year for an additional MIPS Reporting adjustment for outstanding performance is 2022.

As a reminder, this is a budget-neutral program, which necessitates that the fines levied be used to pay the bonus. The greatest positive payment adjustment for a score of 100 points in 2020 was 1.87%.

In rare cases, if CMS determines a performance category is not applicable to a participant, CMS will reweight the performance categories.

Automatic evaluation of the Cost Performance category is done using administrative claim data on 23 episode-based indicators chosen by CMS. Although pathologists and other non-patient-facing professionals are not specifically excluded from the Cost category, CMS warns that many of them may not be able to be linked to a cost metric. For non-patient-facing pathology clinics, the cost performance category has previously been reweighted by CMS to 0%.

Utilizing approved electronic health record technology, the Promoting Interoperability performance area encourages patient participation and electronic information interchange (CEHRT). According to CMS, doctors who don’t see patients, have tiny practices, or work in hospitals will immediately be eligible for a reweighting of this category to 0%.

New automatic reweighting regulations for small practices are being put in place by CMS effective 2022. According to CMS, small practices have 15 physicians or fewer, and big practices have 16 physicians or more.

Quality Scoring Changes

There were no modifications made to the Pathology Specialty Measure Set’s measurements. For 2022, the same six pathological measures that were in place for 2021 will still be in effect. For the 2022 and 2023 performance periods, CMS will likewise maintain the Quality measure data completeness criterion at 70%.

The following scoring modifications for quality metrics have been made by CMS, including:

removing bonus points given for submitting more than the necessary results or high priority measures.
Set a 5-point floor for the second performance period and a 7-point floor for new measures’ first performance periods. New measures typically receive 3 points.
Only if the practice submitted data for another performance area as a group would CMS generate a group score for small practices reporting Quality metrics through claims.
The 3-points-floor is no longer in place for large practices that don’t achieve the 70% data completeness requirement for a given measure. Instead of a scale of 3 to 10, these metrics will be graded on a scale of 1 to 10. The 3-point floor will still apply for small practices when it comes to incomplete data.

Improved New Pathology-Related Activity

Implementing a laboratory preparation plan to support ongoing or increased patient care during COVID-19 or similar public health emergencies is part of CMS’s implementation of the College of American Pathologists (CAP) planned improvement action (IA ERP 5).

8 Important Lessons for Pathology Practice

1. Concentrate on avoiding penalties

The new emphasis on MIPS is more on avoiding a fine than on getting a favorable payment adjustment. At the time the program was first introduced, the objective was to receive the highest score and potentially favorable payment adjustments for Medicare claims. The objective of the program has changed over time, shifting from securing a positive payment to averting a negative payment adjustment.

2. More challenging to reach performance threshold

It becomes more difficult to meet the performance criteria when increases occur each year. Because each measure in the CMS OPP Pathology Specialty Set caps out at 7 points yet is still graded on a 10-point scale, this presents a particularly challenging situation for pathology practitioners.

3. New Measures Score Higher

Only the CAP’s Pathologists Quality Registry tool can be used to provide pathology-specific quality parameters to CMS. These new measurements previously received 3 points since they lacked a standard. The first performance period for new measures in 2022 will provide 7 points, while the second performance period will award 5 points.

4. Measures of the CAP Worth 10 Points

There is now a threshold for two CAP-developed measures that should receive 10 points (CAP28: H. Pylori and CAP 32: Prostate Cancer Gleason Pattern).

5. Bonus for Small Practices

The reweighting of the performance categories to 50% Quality and 50% Improvement Activities should lead to greater results for small practices. Additionally, small businesses will continue to receive 6 Quality Bonus Points.

6. Big Practices Need to Assess CAP Registry

In order to acquire CAP pathology-specific measures worth 10 points, large practices may want to consider evaluating the pathology registry. A large practice’s total score will be 74.5 points if they report on all 6 CMS QPP quality metrics, optimize each one, and obtain full credit for improvement activity.

Large practices that successfully implement all six CMS QPP measures will receive 15 points for improvement activities and 59.5 points for quality [(6 measures x 7 points)/60 total points x 85% x 100]. Total points: 74.5

2 CAP QCDRs and 4 CMS QPP Measures Large practices will gain 68 points for quality [(4 measures x 7 points + 2 measures x 10 points)/60 total points x 85%x 100] and 15 points for improvement activities if they maximize each measure. Total points: 83

7. Keep Improvement Activities in Mind

The most challenging metric for pathologists to assess is quality, which calls for regular group feedback. However, pathology practices must continue to report on improvement efforts in order to meet the performance criterion.

8. Get ready for 2022.

Clinicians who are taking part in MIPS should start planning for 2022 MIPS now and regularly review their MIPS scores. The majority of registry companies have a June deadline and demand yearly registration. Additionally, keeping track of your MIPS score on a regular basis enables physicians to decide how to maximize performance in each category or take action to prevent a penalty.