Policy Primer

2022 QPP updates

MIPS evolves as CMS finalizes larger overhaul

By Ashley Antonelli

November 22, 2021

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.

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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.

Table: Where key changes fall within the QPP

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Three highlights in the final rule

APP: ACOs allowed to use the CMS Web Interface reporting option through 2024, extending the timeline previously finalized

The APP launched in 2021 as a reporting option for clinicians who are part of a MIPS APM, such as an MSSP ACO. Reporting the APP eventually will require participants to submit quality data via MIPS CQMs or eCQMs instead of the CMS Web Interface. For 2022, participants may report at the individual, group, or APM Entity level. Starting 2023, participants also can choose to report at the subgroup level.

Extension of CMS Web Interface through 2024

CMS planned to sunset the CMS Web Interface in 2022, but stakeholders said that shift would pose significant burden. In response, the final rule offers more time for participants to report via the CMS Web Interface, allowing APP participants in an MSSP ACO to report via the CMS Web Interface for program years 2022 through 2024.

Update to the APP Core Quality Measure Set

The final rule also replaces the administrative-claims based measure for Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs with that for MIPS—aligning APP measures with those for MIPS-eligible clinicians who do not participate in APMs. The table below lists the six measures included in the APP Core Quality Measure Set starting 2022.
Traditional MIPS: The performance threshold increases to 75 points in order to avoid penalty and raises the bar on performance in 2022
The 2022 performance year marks a milestone for MIPS. By law, MACRA requires CMS to make certain programmatic changes:

Quality and Cost categories are equally weighted at 30% each.

The performance threshold (PT) is based on the mean or median of scores from a prior performance period. The final rule sets the PT at 75 points for 2022, using the mean final score from the 2017 performance year.

In addition to these required changes, CMS also finalized incremental updates across the MIPS performance categories. The final rule adds new measures to the Cost and Improvement Activities categories starting 2022, but the most noteworthy updates impact the Quality and Promoting Interoperability (PI) categories:

Quality category changes reflect the future of MIPS. CMS is pushing to move beyond policies established in the program’s early years that were intended to ease clinicians’ transition to MIPS. For example, CMS starting 2022 is removing bonus points that previously were available for end-to-end electronic reporting and additional high-priority measures.

PI category changes reflect broader agency goals for data exchange. In light of the Covid-19 pandemic, CMS aims to bolster electronic reporting to public health agencies. These updates echo changes CMS is making to the hospital PI program.

The next two sections include more detail on the most important changes for each MIPS category and a pocket guide showing the PI objectives and measures.

2022 MIPS performance category updates

2022 MIPS PI measures
MVPs: The future of MIPS launches in 2023 with seven MVP reporting options and allows MVP reporting to remain optional until more are available
CMS will launch MIPS Value Pathways (MVPs) reporting in performance year 2023. This new framework aims to reduce reporting burden and make MIPS more meaningful for participants. Its introduction had been delayed due to the Covid-19 pandemic, but the 2022 final rule restarts momentum towards its implementation.

MVP reporting will be optional in 2023. On the surface, some elements of the MVP framework may seem similar to traditional MIPS. But looking deeper into MVP policies reveals several complexities. Clinicians will face many decisions about whether—and if so, how—they should participate. Some of those choices include:

Whether to voluntarily participate in MVP reporting or maintain traditional MIPS strategy;

When to begin MVP reporting if choosing to participate before it is required;

Which MVP to report; and

Within each MVP, which measures to report.

MVP strategy will depend on many factors unique to each participant. Clinicians will need to consider their population health and value-based care strategies, alignment initiatives, data capabilities, reporting resources, and more when deciding how and when to transition to MVPs.

7 MVPs for 2023

Adopting Best Practices and Promoting Patient Safety within Emergency Medicine

Advancing Care for Heart Disease

Advancing Rheumatology Patient Care

Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes

Improving Care for Lower Extremity Joint Repair

Optimizing Chronic Disease Management

Patient Safety and Support of Positive Experiences with Anesthesia

Phasing MVPs in—and traditional MIPS out

The transition from traditional MIPS to MVPs will happen over several years. Clinicians can start in 2023 with voluntary reporting through the seven finalized MVPs. CMS will add more MVP options in future years, aiming to establish a wide range to cover all clinicians by 2028. At that point, CMS will consider sunsetting traditional MIPs and making MVP reporting mandatory.

CMS also intends to phase in MVP reporting at the subgroup level for multi-specialty groups. In program years 2023 through 2025, multi-specialty groups can choose to participate in MVPs at the group or subgroup level. Starting 2026, multi-specialty groups will have to report at the subgroup level if they choose to participate in MVPs. The timeline below includes additional detail on MVP implementation.

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.

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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.

2022 QPP updates

MIPS evolves as CMS finalizes larger overhaul

What is the Quality Payment Program?

Key changes at a glance

Extension of CMS Web Interface through 2024

Update to the APP Core Quality Measure Set

2022 MIPS performance category updates

2022 MIPS PI measures

7 MVPs for 2023

Phasing MVPs in—and traditional MIPS out

What you should do in response

What this means for the program

Have a Question?

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2022 QPP updates

MIPS evolves as CMS finalizes larger overhaul

What is the Quality Payment Program?

Key changes at a glance

Extension of CMS Web Interface through 2024

Update to the APP Core Quality Measure Set

2022 MIPS performance category updates

2022 MIPS PI measures

7 MVPs for 2023

Phasing MVPs in—and traditional MIPS out

What you should do in response

What this means for the program

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Have a Question?

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