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Policy Primer

2022 Proposed Updates to the QPP

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On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) published the 2022 Medicare Physician Fee Schedule (MPFS) proposed rule that updates Medicare Part B reimbursement rates. The 2022 MPFS proposed rule also updates requirements for the Medicare Quality Payment Program, including the program’s MIPS and APM tracks.


What is the Quality Payment Program?

The Quality Payment Program (QPP) is a CMS pay-for-performance program that affects Medicare Part B reimbursement. Clinicians participate in the QPP through two payment tracks:

  • Advanced Alternative Payment Models (APM)
  • Merit-based Incentive Payment System (MIPS)

What is a proposed rule?

Each year, CMS proposes updates to the QPP and solicits public comment through the federal rulemaking process. The policies included in the proposed rule are subject to change. In the coming months, CMS will publish a final rule that will officially establish the program’s policies.

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Key proposals at a glance

The 2022 MPFS proposed rule includes many changes that primarily impact MIPS participants in the QPP. CMS continues to push toward its long-term goal of simplifying and aligning reporting requirements across the agency’s programs. MIPS is evolving through implementation of the APM Performance Pathway (APP) and MIPS Value Pathways (MVPs). At the same time, MIPS performance standards will increase in 2022. For example, the proposed rule sets a higher threshold required to avoid penalties. CMS also updates policies within each performance category, including removing bonus points in the Quality category.

The table below shows where key proposed changes fall within the QPP.

Three highlights in the proposal
  • APP: Temporary extension for CMS Web Interface
  • MIPS: Raising the bar on performance
  • MVPs: The future of MIPS

What this means for you

Each year, the proposed rule offers eligible clinicians a glimpse into future program requirements. While these policies are subject to change in the final rule, participants should plan ahead for potential changes. Use this checklist to guide your strategy.

1 Maximize MIPS performance score

  • Evaluate opportunities to boost your score across performance categories. For example, consider reporting the following optional PI measures:
    • HIE bi-directional exchange measure;
    • Query of PDMP measure; or
    • One of the public health measures—Public health registry, Clinical data registry, or Syndromic surveillance.
  • Aim for the exceptional performance threshold of 89 points to maximize your positive payment adjustment, as 2022 is the final year the additional incentive is available.
  • Redeploy any resources allocated toward end-to-end electronic and/or high-priority bonus points to measures with potential for performance improvement.
  • Consider whether the new Cost category measures apply to you and devote resources accordingly.

2 Evaluate your reporting strategy

  • As traditional MIPS becomes more challenging, consider the opportunity for preferential reporting and scoring policies through APP reporting available to MIPS APM participants.
  • For MIPS APM participants, continue to implement MIPS CQMs or eCQMs to support APP reporting and assess whether CMS Web Interface reporting is necessary as a backup.
  • Review MVP reporting options and consider whether to participate for performance year 2023 or to continue reporting through traditional MIPS.
  • Prioritize MVP measures that align with organizational quality initiatives.

3 Submit public comment

  • Provide your feedback to CMS via public comment by Sept. 13, 2021. See the next section for our guidance on which MIPS and MVP proposals you may wish to address.

Submit public comment on the proposed MIPS updates

We encourage participants to offer their feedback on the substantial number of proposed changes to traditional MIPS policies and help shape the continued development and implementation of the MVP framework. On the traditional MIPS side, consider pushing CMS to minimize any updates beyond those required by statute. On the MVPs side, consider providing feedback on how the framework might work in practice. Overall, it’s worth noting that clinicians have limited capacity to address policy changes given the continuing Covid-19 pandemic.

Participants also must evaluate how CMS’ proposed changes may impact their long-term MIPS strategy. While not exhaustive, this list can help participants prioritize policies for public comment.

Public comment due by Sept. 13, 2021


  • Extension of CMS Web Interface reporting option
  • Alignment between MIPS PI and updates to hospital PI
  • Doubling the complex patient bonus, along with broader policies to inflect health equity
  • Policies to align quality measure scoring across traditional MIPS, the APP, and MVPs


  • Keep Quality bonus points, and/or establish alternative incentives for end-to-end electronic reporting and additional high priority measures prior to removing bonus points
  • Use historical Quality measure benchmarks, rather than 2022 performance period benchmarks
  • Delay increasing the Quality data completeness requirement
  • Extend overall timeline for MVP implementation
  • Reconsider or delay subgroup reporting requirement for multispecialty groups participating in MVP reporting
  • Only require MVP registration for subgroup reporting level

Seek clarification

  • Whether participants should reconsider reporting of measures without a benchmark, if removing the 3-point floor
  • How will the SAFER Guides measure requirement fit into long-term requirements for PI performance
  • MVP reporting policies for multi-specialty groups, such as whether they must report on more than one MVP if multiple options are applicable
  • How will CMS enforce its requirement for third-parties, such as EHR vendors and registries, to support MVP reporting

What this means for the program

This proposal contains two major themes throughout: delaying the timeline for several significant planned changes to MIPS while also raising the bar on performance in the near term. The delays are unsurprising, as CMS has looked to minimize change while clinicians respond to the continuing Covid-19 pandemic. But CMS is still moving forward with top priorities to drive continued improvement in care quality and, ultimately, to prepare clinicians for APM participation.

The proposals place MIPS participants at a series of crossroads. Over the next several years, participants must decide how to dedicate strained resources to both performing well in traditional MIPS and to preparing for the transition to MVPs. It’s a good reminder that MIPS is designed to become more challenging over time. Looking forward, MIPS participants should consider whether joining an APM would make strategic sense, in terms of both their QPP participation and broader value-based care goals.

The arrival at this crossroads is perhaps timelier than ever: The Covid-19 pandemic surfaced the financial instability that can come with relying on volume-based revenue through fee-for-service payments. Many health systems leaders are taking a renewed interest in the potential for financial stability and flexibility that can come with APM arrangements. The next few years will reveal whether the industry has reached a tipping point toward joining APMs, and if so, how that impacts the dynamics of QPP participation.

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