2022 MIPS Proposed Rule:
General Observations

2022 MIPS Proposed rule update

By: Barbara Rubel, MBA, FRBMA, Sr. VP, Marketing and Client Services
July 30, 2021


CMS anticipates COVID-19 will continue to affect clinicians throughout the rest of the Performance Year 2021.  CMS is allowing individual clinicians, clinician groups and virtual groups to apply for an Extreme & Uncontrollable Circumstances (EUC) exception to reweight one or more performance categories for PY 2021.  If both an EUC application and performance data for a category are submitted, the data will override the EUC application.

MIPS Proposed Category Weights

  • Quality: 30%
  • Cost: 30%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%

The proposed rule continues to offer category reweighting for clinicians who cannot submit data for one or more categories.

MIPS Proposed Performance Thresholds

  • Performance Threshold to Avoid a Penalty: 75 (increase from 60 in 2021)
  • Exceptional Performance Threshold to earn additional bonus: 89 (up from 85 in 2021)
  • Maximum Payment Adjustments: -9% (negative) and 4%-15% (positive)

Low Volume Threshold

To be excluded from MIPS in 2022, eligible clinicians need to meet one of the following three criteria:

  • ≤ $90K in allowed charges for covered professional services. or
  • Provide covered care to ≤ 200 beneficiaries, or
  • Provide ≤ 200 covered professional services under the MPFS.

There are no changes to the opt-in policy which allows physicians who meet some, but not all, of the low-volume threshold criteria to opt-in to MIPS. 

Small practice bonus of 6 points is maintained (included under Quality).

Small practices awarded 3 points for submitted quality measures that do not meet case minimum requirements or do not have a benchmark.

Claims-based reporting for small practices continues in 2022.

Small practices defined as </=15 clinicians.

Measure Scoring

CMS proposes three major changes in PY 2022:

  1. Change scoring range for benchmarked measures to 1 to 10 points, eliminating the 3-point floor.

  2. Non-benchmarked measures score 0 points even if data completeness is met.

  3. For new measures which do not yet have a benchmark, the scoring floor will be raised to 5 points for their first 2 years in the MIPS program.

    • These new measures will still achieve higher points if a same-year benchmark is established, but if a benchmark isn’t established after 2 years in the program, that measure will earn 0 points.
    • Exception: small & rural practices will be awarded 3 points for measures which either do not have a benchmark or do not meet case minimum.

CMS has also proposed ending awarding bonus points for high priority and end-to-end measures.

Quality measures reported by Radiologists that have been deleted:

  • #21: Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second Generation Cephalosporin

  • #23: Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients)

  • #144: Oncology: Medical and Radiation – Plan of Care for Pain

  • #154: Falls: Risk Assessment

  • #195: Radiology: Stenosis Measurement in Carotid Imaging Reports

  • #225: Radiology: Reminder System for Screening Mammograms

  • #317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented

Topped Out Measures

  • Continue capping measures at 7 points (out of a possible 10) if measures have been topped out for 2+ performance years

  • CMS will adjust the score if the measure ceases to be topped out upon completion of data submission for the current performance year

Data Completeness

No changes for 2022. Quality measure submission must continue to account for at least 70% of total exam volume.  This number defines the minimum subset of patients within a measure denominator that must be reported.  CMS proposes increasing this threshold to 80% beginning with the 2023 performance year.

Improvement Activities

7 new activities added, 15 existing activities modified, and 6 previously adopted activities removed.

Facility-Based Scoring:

No changes

MIP Value Pathways (MVPs)

7 MVPs proposed for 2023 – none for Radiology; however, MSN is working on the development of a Radiology MVP.

Proposed MVP Clinical areas for 2023:

  • Rheumatology
  • Stroke care & prevention
  • Heart disease
  • Chronic disease management
  • Lower extremity joint repair (e.g., knee replacement)
  • Emergency medicine
  • Anesthesia

CMS is seeking comment on removing “traditional” MIPS at the end of the 2027 performance/data submission periods.

Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

Barbara has been a leader with MSN Client Services since 1998. Her extensive background in strategic planning, market research, healthcare marketing and managed care negotiations provides a wealth of information to support MSN Clients.

Barbara has also been highly involved in industry organizations, serving as President of the Radiology Business Management Association (RBMA), the Georgia RBMA, and the Florida RBMA. In addition, she chaired the influential RBMA Federal Affairs Committee and the RBMA Technology Task force and was a member of the RBMA Data Committee. Her work on behalf of radiology has earned her the RBMA Special Recognition Award (2010), the RBMA Global Achievement Award (2013), and she is a Fellow of the RBMA.