Medicare Compliance & Reimbursement

But: Policies do promote an easier transition to MVPs for 2023.

You might feel as though Medicare likes to overhaul programs just as providers finally figure out how things work. The 2022 Quality Payment Program (QPP) final rule highlights this perennial problem as the feds lay the groundwork for their major shift from the Merit-Based Incentive Payment System (MIPS) to MIPS Value Pathways (MVPs) in the coming years.

Background: On Nov. 19, the Centers for Medicare & Medicaid Services (CMS) published the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) in the Federal Register. The annual policy opus includes QPP changes for next year — or in this case, years, as CMS offers guidance on the transition from traditional MIPS to MVPs. The QPP 2022 follows along the same vein as other MPFS policies, reducing providers’ burdens while bolstering health equity.

“MIPS aims to drive value through the collection, assessment, and public reporting of data that informs and rewards the delivery of high-value care,” notes the 2022 QPP final rule fact sheet. But according to stakeholder feedback, traditional MIPS was too confusing and burdened clinicians with too many tasks. Providers asked for a program that not only supported their medical specialties but also improved patient care.

“The Physician Fee Schedule final rule advances all these strategic priorities and helps build a better Medicare program for the future,” says CMS Administrator Chiquita Brooks- LaSure in a release.

Understand the MVP Transition Basics

MVPs grew from years of comments on how to tweak MIPS, but CMS decided to implement the new program slowly starting in CY 2023, the final rule suggests. Even though MVPs are still in a transition phase and the agency plans to sunset traditional MIPS eventually, CMS encourages MIPS-eligible clinicians to begin setting up new protocols and policies now to ensure success.

“This [implementation] flexibility allows organizations and clinicians to determine whether they are ready to make the transition to MVP reporting or continue to report traditional MIPS, considering their resources that are dedicated to caring for patients during the PHE,” the rule notes. “Since we did not propose a definitive timeframe to which MVP participants must transition to MVP reporting or to sunset traditional MIPS, we believe our proposed policies include sufficient flexibilities for organizations and clinicians.”

Additionally, voluntary MVP reporting allows participants extra time to prepare staff and third-party vendors for adoption of the new program, the QPP fact sheet suggests.

Add These Traditional MIPS Updates to Your Wheelhouse

With MVPs slated to commence in CY 2023, you still need to focus your measures reporting for the MIPS performance year 2022/payment year 2024. Here’s the lowdown on five points you need to keep a handle on for the new year:

1. Performance threshold: CMS used the 2017 performance year stats to determine the bump from 60 points to 75 points for CY 2022 final scores, implies the QPP fact sheet. The exceptional performance threshold will be set high at 89 points next year.

“We note that under section 1848(q)(6)(C) of the Act, the additional MIPS adjustment factors for exceptional performance are available through the 2022 performance year/2024 MIPS payment year, making this the last year of the additional performance threshold and the associated additional MIPS adjustment factors for exceptional performance,” CMS cautions.

“Moving forward, [the] MIPS performance threshold must be set on mean or median performance,” explains Suzanne Michelle Joy, senior public affairs advisor, with law firm Holland & Knight LLP in online analysis of the rule. Plus, “CMS made the complex patient bonus methodology more challenging in part by adding a social complexity element and terminated the high-priority measure and e-prescribing bonuses,” Joy adds.

2. MIPS ECs: Social workers and certified nurse-midwives can now count themselves among the MIPS-eligible clinicians’ ranks. Both will have the appropriate number of Quality measures available to report as well as applicable Improvement Activities for CY 2022, but CMS is “automatically reweight[ing] the Promoting Interoperability performance category to 0 percent for clinical social workers,” the QPP fact sheet says.