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Policy Primer

2022 QPP updates

20 Minute Read

On Nov. 19, 2021, the Centers for Medicare & Medicaid Services (CMS) published the 2022 Medicare Physician Fee Schedule (MPFS) final rule that updates Medicare Part B reimbursement rates. The 2022 MPFS final 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)

Key changes at a glance

The 2022 MPFS final 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 while aiming to drive continued improvement in quality of care. 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 final rule sets a higher threshold required to avoid penalties. In addition, CMS is updating policies within each performance category, including removing bonus points in the Quality category.

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

Three highlights in the final rule
  • APP: ACOs allowed to use the CMS Web Interface reporting option through 2024, extending the timeline previously finalized
  • Traditional MIPS: The performance threshold increases to 75 points in order to avoid penalty and raises the bar on performance in 2022
  • MVPs: The future of MIPS launches in 2023 with seven MVP reporting options and allows MVP reporting to remain optional until more are available

What you should do in response

Use this checklist to guide your 2022 QPP strategy. These are the main areas on which to focus in response to this year’s final rule.


What this means for the program

The final rule shows CMS is committed to moving the QPP forward in ways that aim to drive continued improvement in care quality and nudge providers toward APM participation. CMS made these priorities evident by finalizing plans to raise the bar on MIPS performance in the near term and overhaul the program over the next several years with MVPs. The MVP pathway is designed to better align MIPS reporting with the APM track, essentially giving clinicians an on-ramp to how reporting generally works for an APM. Once clinicians get that experience through MVP participation, they may find they’re more prepared to make the leap to an APM—moving them forward in value-based care.

But CMS also recognizes that making these reporting shifts can be burdensome, and the agency is listening to stakeholder feedback on how it can ease these transitions. When it comes to MVPs, for instance, CMS pushed back by one year its subgroup reporting requirement for multispecialty groups that voluntarily participate in the new pathway. And for the APM Performance Pathway (APP), CMS delayed its plan to sunset the CMS Web Interface, allowing MSSP ACOs more time to transition to MIPS CQM/eCQM reporting under the APP.

However, although CMS is willing to slow its plans for the biggest changes to the QPP—especially in light of the ongoing strain placed on providers by the Covid-19 pandemic—the agency remains bullish on steadily moving providers toward value-based care arrangements. We expect that to remain a priority in coming years—meaning if you haven’t yet, now is the time to explore your APM options.

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