MIPS requirements for 2022
Answers in Practice
By Faiza Wasif, MPH, Associate Director, Practice Management, June 1, 2022
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff discuss MIPS requirements.
CMS published new requirements for the Merit-based Incentive Payment System (MIPS) for 2022. Review a summary of highlights below to prepare for these changes.
Payment adjustment
The penalty for not participating in 2022 will remain 9% as required by law, applied to reimbursements in 2024. See the full program timeline below.
Eligibility criteria
The low-volume exemptions for participation in MIPS remain the same as 2021:
Bill ≤ $90K in Part B allowed charges for covered professional services, OR
Provide care to ≤ 200 Part B enrolled beneficiaries, OR
Provide ≤ 200 covered professional services under the Medicare Physician Fee Schedule
The voluntary opt-in option remains, allowing some clinicians, who otherwise would have been excluded under the low-volume threshold, the option to participate in MIPS. Eligible clinicians or groups will be able to opt in if they meet or exceed at least one or two, but not all three, of the low-volume threshold criterion noted above.
Eligible clinicians should confirm their eligibility status on the Quality Payment Program (QPP) website.
MIPS reporting options
The print version of this article included a large table of reporting options. Please see the online version of this table, which is divided by the size of your practice.
Performance thresholds
The threshold to avoid the penalty has increased in 2022. The minimum score to avoid the penalty is 75 points, up 15 points from 2021, and the minimum score to achieve the maximum incentive is 89 points, up 4 points from 2021.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or virtual groups. As in years past, for the 2022 performance period, the virtual group election should have been made by Dec. 31, 2021. To participate in MIPS as a virtual group, an election must be made prior to the start of the performance period and can’t be changed once the performance period begins.
Beginning in 2022, small practices, excluding those participating in MIPS as part of a virtual group, must submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.
Performance categories and performance periods
Quality and Cost performance category weights have changed, while Improvement Activities and Promoting Interoperability weights remain the same. Also, the performance periods remain the same in 2022 as they were in 2021. See details below.
Quality: 30% (10% decrease in category weight from 2021)
Data completeness remains at 70%
12-month calendar year performance period
Improvement Activities: 25% (same as 2021)
Group participation threshold remains at 50% of eligible clinicians
Consecutive 90 days minimum performance period; last day to begin participation is Oct. 3, 2022.
Promoting Interoperability: 25% (same as 2021)
Consecutive 90 days minimum performance period; last day to begin participation is Oct. 3, 2022.
Cost: 30% (10% increase from 2021)
12-month calendar year performance period; no action needed by eligible clinician. CMS will automatically calculate and apply a score.
2022 MIPS category weights and redistributions
View a breakdown of 2022 MIPS category weights and weight redistributions at staging.aad.org/mips-reweighting.
Small-practice accommodations
The 2022 accommodations for small practices (15 or fewer physicians) include:
3 points for measures that do not meet the 70% data completeness requirement
Claims reporting available for the Quality category
6 bonus points added to the Quality category
Automatic redistribution (no application required) of the Promoting Interoperability performance category weight for any small practice that does not submit data for the performance category:
When Promoting Interoperability is redistributed, Quality will be 40%, Cost 30%, and Improvement activity 30%
When Promoting Interoperability and cost are both reweighted, quality will be 50% and Improvement activity 50%
Extreme and uncontrollable circumstances
CMS will once again apply the MIPS automatic extreme and uncontrollable circumstances policy to ALL individually eligible MIPS eligible clinicians during the public health emergency due to COVID-19. Applications will be available on the QPP website.
Note: Starting in 2022, if dermatologists perform 10 or more melanoma resections that meet the eligibility criteria for this measure, CMS will automatically apply these to the Cost category and assign a score up to 30% of the overall MIPS score. If an eligible clinician does not perform 10 or more melanoma resections in the performance year, they will automatically be exempt from the cost measure, and the weight of this category will be redistributed to other categories. View more information on Cost.
Each year, the MIPS program requirements become more stringent. To maximize your chances of success, eligible clinicians are highly encouraged to adopt an electronic health record (EHR). By adopting an EHR, you can meet the minimum requirements to avoid the penalty and integrate with the Academy’s clinical data registry, DataDerm™, to make reporting seamless and to minimize the risk of errors. Learn more about DataDerm. Find an EHR that fits your needs to optimize your practice workflow. If you already have one, learn how to maintain or enhance it.
Finally, as you navigate the reporting option that works best for you and your practice, explore the MIPS step-by-step guide to learn more about the program and each performance category.
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