How to Avoid a MIPS Penalty: 2022 Performance Year

It’s the start of a new year with a renewed focus toward managing MIPS performance in 2022.  The purpose of this blog is to review how to avoid MIPS penalties.

Avoiding a MIPS penalty can have a huge impact on your bottom line. Penalties for failing 2022 MIPS range up to 9% levied on your 2024 Part B professional service reimbursements.

Penalty avoidance strategies can be split based on whether or not you are going to report the Promoting Interoperability (PI) category and whether or not you will be picked up in the Cost performance category.

New for 2022: Strategies also differ in approach for smaller practices versus large practices because of changes in the scoring redistribution policies for small practices that take a PI hardship that decrease the weight redistributed to the Quality category.

Let’s look at this further. Once you determine which category you fall into, use this handy guide to review your requirements.

PI: To Report or Not to Report?

New in 2022, if you are a small practice (15 or fewer clinicians) you will automatically receive a hardship for the PI category unless you submit 2022 PI data.

If you are in a larger practice, you can apply for a PI hardship is extenuating circumstances created an inability to perform the PI measures. For more information, visit CMS’s hardship information page.

If you don’t report PI, this is how your category weight will be redistributed.

Will I Get Scored in 2022 MIPS Cost?

It depends. In order to be scored on Cost, you must be eligible for at least one of the 25 Cost measures. Two measures are general measures:

  • Total per Capita Cost (TPCC): this measures the overall cost of care delivered to a patient with a focus on the primary care they receive from their provider(s). The measure is a payment-standardized, risk-adjusted, and specialty-adjusted measure.
    • 56 specialties and subspecialties are excluded from this measure, including ophthalmology, dermatology, and orthopedic surgery. For a full list, see the CMS TPCC codes spreadsheet, Eligible_Clinicians tab.
    • If you are group reporting and have PAs, NPs, CRNAs, or other clinicians eligible for TPCC, your group will be scored on this measure.
  • Medicare-Spending per Beneficiary (MSPB): this is measures cost related to inpatient care. If neither you nor anyone else in your group (if group reporting) provides inpatient care, you should not be scored on this measure.

The remaining 23 measures are episode-based Cost measures that measure costs related to specific episodes of care. For example, one of these is the Cataract episode-based cost measure. This is the only ophthalmology-specific cost measure.

If you meet the criteria to be scored on any of the 25 Cost measures, Cost will comprise 30% of your MIPS Final Score.

If you are not eligible for any of the Cost measures, your Cost category weight will be redistributed to Quality.

In 2022, ophthalmology-only practices that don’t perform cataract or do eyelid melanoma excisions or repairs will be excluded from Cost.

Outpatient dermatology-only practices that do not do melanoma resections other than Mohs and do not have NPs or PAs who bill under the practice TIN will be excluded from Cost.

How Can I Report Quality?

If I Have an EHR?

You can report electronic clinical quality measures using EHR data either through your EHR or through a registry.

Qualified clinical data registries (QCDRs) are able to offer additional QCDR measures under MIPS. These are measures developed by the QCDR. They are usually specialty-specific measures that offer specialists more germane and meaningful measures to report under MIPS.

To report through your EHR, contact your EHR to find out more. To report through a QCDR, consider reaching out to your specialty society. For a complete list of 2022 QCDRs and measures they offer, check out this 2022 QCDR list publication from CMS.

If I Do Not Have an EHR?

You can report quality measures via claims or through a registry. Claims-based measures are harder to do well on in general and offer very little variety. A more well-rounded option is to report through a registry. Check with your specialty society to find out more about the 2022 manual MIPS reporting options available to you and what steps you can take to make manual Quality reporting easier.

Next Steps

  • Share this information with your practice colleagues.
  • Contact your Client Success Manager if you have any questions.
  • If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

If you have any questions on this, let us know!

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