Anesthesia and MIPS 2022

explaining anesthesia and mips 2022

Anesthesia and MIPS 2022

Why most practices will get hit with a penalty

As the CMS’ MIPS program approaches the upcoming year, many anesthesia practices are unaware of the subtle program changes that will make achieving a bonus and averting a penalty much more difficult, should the CMS Proposed Rule become “Final” in early November. This article is intended to provide clarification on this matter and offer strategies to optimize your results.

QR vs QCDR: Understanding the Difference

The most important thing to understand in this area is the difference between the terms “Qualified Registry” (QR) and “Qualified Clinical Data Registry” (QCDR).

Both these registry types are acceptable for your annual MIPS submission to CMS. However, QRs are limited to reporting national MIPS measures only and cannot develop measures of their own or license measures from other registries, as QCDRs can.

In practical terms, this means that QRs have a much smaller menu of MIPS measure options for you to choose from. The other interesting item of note is that the national MIPS measures available for anesthesia have been around since the inception of MACRA (2017), meaning that they’ve been reported by many groups for the past 4 years and are now considered as “topped out” or devalued.

Bonus Points

Another nuance to the MIPS scoring system is bonus points. Historically, anesthesia groups who reported on “High Priority Measures” received up to 5 bonus points, which was applied to their quality category. This helped to increase practices’ MIPS composite scores and achieve bonuses. The 2022 CMS Proposed Rule would eliminate these quality bonus points entirely, making it difficult to avoid a penalty and impossible to get exceptional-performance-bonus money without reporting through a QCDR.

Anesthesia Measures Available Through QR Reporting

The table below shows the national anesthesia measures available through QR reporting. As you’ll notice, there are only 7 to choose from, and one (#44) is scheduled to be retired at year’s end. 

Even more alarming is the maximum score that you’ll get from reporting on such measures in CY 2022. Best case scenario – you’ll get a composite score of 77.33, which falls well short of the exceptional performance bonus threshold (89) and dangerously close to the penalty threshold (75). Worst case scenario – you’ll score below a 75 and get hit with a penalty of up to 9% on your Medicare collections in 2024, after all that work!

Anesthesia and MIPS 2022 chart

There's Still Time

On the bright side, you still have time to change course and move to a QCDR, if you’re not already reporting through one. QCDR’s offer additional measure options which are more highly valued than national measures, allowing your practice to optimize your MIPS composite score and achieve a bonus.

MSN Healthcare Solutions was the first anesthesia billing company to be approved by CMS as a QCDR and currently has 14 highly weighted MIPS anesthesia measures available for reporting in 2022. For more information, please contact Hal Nelson at (470) 955-1967 or

Hal Nelson, Vice President Anesthesiology Services


Hal Nelson, CANPC
has 30 years experience on both the payer and RCM side, with a focus in Anesthesia. He formerly worked as a senior claims approver at United Healthcare, as well as a compliance officer for multiple national billing companies. He has also taught the CPC coding curriculum collegiately in Atlanta. His broad based experience ensures that MSN clients will have a resource for documentation and billing issues. His past speaking engagements include ASA, MGMA, Dartmouth, and Johns Hopkins.