This year brings a new set of challenges and obstacles to success in MIPS as the performance threshold increases to 75 points. There are also additional changes and challenges to be aware of as you navigate the program this year – bonuses ending, an increased focus on cost, and a ±9% range for potential adjustments.
Add to this the difficulty of the lingering effects of the COVID-19 pandemic, and we’re looking at a tough journey in the MIPS program this year. While this sounds overwhelming, this blog post is a great place to start and should alleviate some uncertainty.
In the next section, we’ll look at changes and challenges.
Later, we’ll dive into reasons to be hopeful and ways you can increase your chances of success.
MIPS in 2022: The Hardest Year Yet.
Before we get into the specific challenges, reasons to be hopeful, and path to success, let’s talk about the bad news. 2022 is the hardest year yet in the MIPS program.
Here are a few of the main drivers of difficulty in MIPS this year:
- The End-to-End Electronic Reporting and High Priority Measure bonuses are gone in 2022, so you will not be able to rely on those to affect your score.
- This is the final year for the Exceptional Performance bonus, and the threshold is now at 89 points.
- All Medicare reporting clinicians are now MIPS eligible this year.
- Cost now makes up 30% of your score – the Cost category was reweighted to 0% for Performance Years 2020 and 2021, so the impact of this category will be significant in 2022.
- The Performance Threshold is now 75 points – you’ll have to score at least 75 points to avoid a penalty. If you can’t meet or exceed this threshold, you can decrease your penalty by scoring as close to 75 points as possible.
- And finally, the range of Potential Adjustments is ±9% for 2022.
If you’re feeling overwhelmed by these details, there’s one more piece of bad news: the COVID-19 pandemic has had a significant impact on the rollout of the MIPS program. The Performance Year 2022 is more challenging because the program is meant to increase in difficulty as it goes along — but this increase in difficulty has been “masked” by the pandemic. In 2020 and 2021, as we worked to overcome challenges related to COVID-19, CMS adjusted the MIPS program to account for the increased difficulty of navigating the pandemic. While understandable and appropriate, these adjustments removed the “ease-in” phase of the program. Instead of experiencing a gentle increase in difficulty as the program progressed, we’re met with a sudden snap of greater difficulty for 2022.
A switch in perspective: The MIPS program will never be easier.
Let’s reiterate an important point before we move on: MIPS was designed to increase in difficulty as the program progressed.
So, while 2022 is indeed the hardest year yet, it will never be easier than it is right now.
Here are a few ways the MIPS program will likely be more challenging in the coming years:
- The 3-point floor on Quality Performance measures will disappear after 2022. Currently, you can’t score less than 3-points on any submitted measure. This floor will be removed after this year.
- The Data Completeness Threshold will likely increase in the coming years. This is currently at 70%, and it’s reasonable to expect it to rise to at least 80%.
- The Web Interface reporting method will end for MIPS groups after 2022. This will make it harder for complex groups with multiple EMRs to report and generate Quality statistics.
- We can expect more episode cost measures in the coming years.
- Cost will continue to have a more significant impact on your annual adjustments. We have not yet experienced an entire year where cost has substantially impacted payments – we will see it become increasingly significant in the coming years.
- MIPS Value Pathways (MVP) will be operational in 2023. This will be a major change and a dramatic increase in difficulty for multi-specialty groups.
- We will likely see increased Interoperability and Patient Access requirements in the coming years.
This look toward the future of MIPS shouldn’t be discouraging. In fact, it should be motivational.
The sooner you can build a strategy tailored to your organization’s needs, requirements, and goals, the better off you’ll be in MIPS. An increased understanding and higher performance this year will likely lead to better performance in the coming years.
Now let’s talk about what to expect in 2022.
What challenges can you expect in MIPS this year?
You can increase your chances of success in MIPS this year by starting with a clear understanding of the challenges you’re likely to encounter. The specific obstacles to overcome will be different for all organizations – you’ll have a unique set of hurdles and circumstances – but we can broadly filter most challenges into two general areas.
Area One: Competing Priorities
The first challenge to be aware of is that the design of the MIPS program requires you to build and maintain a balanced approach to each performance category. To navigate the program and increase your performance, you will have to pay appropriate attention to each category. Too much attention to one, and others will suffer. And completely neglecting any category will lead to increased chances of penalty.
Set yourself up for success by creating a clear understanding of your priorities regarding MIPS performance and the amount of time and resources you’re willing to put toward that performance. Make sure your priorities are easy to communicate and understand across your entire organization.
Area Two: Competitive Payment Adjustments
The next challenge category that you will undoubtedly face is the competitive nature of scoring in the MIPS program.
Remember this major element of the MIPS program: it’s designed to be budget neutral.
What does that mean?
CMS uses the penalties from lower-scoring organizations to pay the positive payment adjustments to higher-scoring organizations. In the MIPS program, you compete against practices across the country to avoid penalties and gain a bonus.
Once again, the MIPS program was designed to encourage this competition with the idea that if there is a competition to avoid penalties and gain a positive adjustment, this will lead to better performance from all organizations participating in MIPS.
You cannot avoid this competition in MIPS, so you need to prepare for it and build a strategy that allows your organization to stack up against your competitors.
Now that you have an idea of the general challenges, let’s look at your path to success.
Build your Strategy: The Path to Success in MIPS in 2022.
You can still put yourself on the right path in MIPS this year. It’s not easy, but you can increase your chances of success by working on a few key steps:
- Gain situational awareness: it’s vital that you continually increase your understanding of rules, specifications, benchmarks, and unique challenges in your organization. You want to build a habit of learning more about MIPS and how the program works while also becoming familiar with your organization’s circumstances concerning MIPS and how you can increase your chances of success in the program. (Our webinar on the 2022 Final Rule is a great place to start.)
- Additionally, understand that there are rule changes every year, and CMS will sometimes even change their interpretation of the rules. Build an understanding that allows you to adapt and adjust to program changes.
- You’ll also want to keep track of key dates and deadlines throughout the year. Here’s a resource to bookmark that will help you do that: Important MIPS Reporting, QPP, and Value-Based Care Deadlines
- Build a system: you want to create a reliable, predictable method that allows you to approach any measure and track any characteristics without significantly overhauling your workflow. You don’t want to jury-rig your approach to a measure and then change that approach when you select a new measure next year. You want to have a system that works reliably and can be improved consistently over time while allowing you to measure anything that you decide to track.
- Some additional notes on building systems:
- For quality measurement, you want systems that are extensible, scalable, adapt to emerging medical evidence, and translate to point-of-care decision support and gaps-in-care analysis.
- For systems to control cost, you want to understand the frequency and venue of visits (move toward less expensive options), referral dynamics, and keeping up with emerging medical evidence.
- For engaging patients, you want reliable, comprehensive systems that enable self-care when possible and appropriate.
- Finally, build documentation and analysis into all your systems. A system that you can’t understand, track, and improve is as helpful as no system at all.
- Some additional notes on building systems:
- Simplify: while building systems, you want to strive to make them simple. You don’t want multiple systems that do the same thing or systems that are tough to explain and understand. You want to work toward simplification and increased understanding of your processes and workflows at every opportunity.
- Integration: Finally, find ways to integrate your MIPS understanding, systems, and workflows into your organization. Find ways to align your priorities and processes so that the right choice is the simplest and easiest choice. Integrating your MIPS strategy and workflows across your organization means that your approach will not be disjointed or broken when new problems arise.
Start today: a few steps you can take right now.
Of course, your performance in the MIPS program is an ongoing, adaptive process. But you can mitigate penalties and increase your performance today by doing a few things right now.
- As you’re building your systems to maximize MIPS performance, you should be aligning your performance management with compliance reporting programs like MIPS.
- You should proactively analyze your data and track performance in the measures that matter to your organization. This means that you should be viewing your data at least quarterly, but hopefully monthly, and in some cases, weekly.
- Keep an eye on changes in the MIPS program throughout the year and pay particular attention to the changes that will likely affect your organization – specialty-specific changes are a good example.
- Pay attention to trends. You’ll be able to notice trends from CMS year-over-year, and Mingle Health works to help you see, understand, and adapt to changing trends in the Value-Based Care landscape.
On that note, let’s take a moment to explore how Mingle Health can help you navigate the MIPS program while mitigating penalties and increasing your chances of success.
Your Partner in MIPS and Value-Based Care.
From the beginning, our goal at Mingle Health has been to help you succeed in Value-Based Care programs. Our team of experts and easy-to-use technology make navigating MIPS, Primary Care First, and other APMs accessible and understandable.
When your organization partners with Mingle Health, you’ll gain access to a dedicated Mingle Consultant that works with you throughout the year to increase your performance in MIPS. Your consultant will understand your strengths and weaknesses and help you work toward your strengths.
We’ll help you set rational goals – whether you want to receive a bonus, avoid penalties, or decrease the penalties you can’t avoid. Mingle Health has a proven track record of helping organizations maximize gains and minimize losses in the MIPS program.
Mingle Health can capture and report data from any system you use. We meet you where you are and adapt to your circumstances so you can make a great submission every year, no matter the system.
And finally, we help you navigate MIPS – or any other Value-Based Care program – without the confusion, hassle, and stress. With Mingle Health on your side, you can be confident in your ability to make the best submission possible in your circumstances while increasing your understanding, systems, and performance in the future. Click here to learn more about our MIPS Solutions and find out how we can help your organization stay on the right track this year >>
Click the button below to access the recording of our latest webinar - "The Hardest Year Yet: Your MIPS Success in 2022" - where Dr. Dan Mingle provides a deeper exploration of the information in this blog post.