MIPS Changes for 2022

Below we have outlined changes to the Merit-Based Incentive Payment System (MIPS) that were included in the Final Rule for the 2022 Physician Fee Schedule released by CMS.  We have included those aspects that will affect the rehab therapy industry. 

The “MIPS Value Pathway” (MVP) has been mentioned over the last few years and was set to be implemented in 2022.  CMS has decided to postpone the transition to MVP until 2023.

For 2022, the changes that will impact PT, OT and SLP reporting of MIPS are as follows:

Performance Categories

For rehab therapists (PT, OT, SLP), Cost and Promoting Interoperability Categories are not being reported, and the value for those categories are reweighted to the “Quality” category. 

The % remains the same as from Performance Year 2021:

  • Quality: 85%
  • Improvement Activities: 15%

Performance Threshold 

75 points (neutral adjustment) (increased from 60 points in 2021)

Additional Performance Threshold: 89 points (exceptional bonus) (increased from 85 points in 2021).

  • Data Completeness – MIPS eligible clinicians will continue to meet the current data completeness threshold of 70% (e.g., must report at least 70% of eligible cases for each Quality measure) for the 2022 and 2023 performance periods.
  • Quality Measure Scoring – Scoring updates will be applied to new measures and measures that do not meet case minimum and data completeness requirements, and measures that do not have a benchmark.
  • New Quality measures – In 2022 a 7-point floor is established for the first performance period and a 5-point floor for the second performance period for new Quality measures.

Beginning with the 2023 performance period:

  • Measures with a benchmark – The 3-point floor is removed for measures that can be scored against a benchmark. These measures will receive 1-10 points.
  • Measures without a benchmark – The 3-point floor is removed for measures without a benchmark (except small practices). These measures will receive 0 points (small practices will continue to earn 3 points).
  • Measures that don’t meet case minimum requirements (20 cases) – The 3-point floor is removed (except small practices). These measures will earn 0 points (small practices will continue to earn 3 points).

There is one significant change to the Quality Process Measures that directly impacts PT and OT: 

#154 Falls: Risk Assessment is being removed.

Due to the points needed for just a neutral adjustment to occur, it is HIGHLY recommended that any therapists required to participate in MIPS (or any that are choosing to opt in) sign up with a QCDR to submit MIPS measures on your behalf.

If using a QCDR like FOTO or PTOR (full interface with OptimisPT for MIPS data submission), you have the availability to report a full library of outcome measures, with all of them being benchmarked for the 2022 performance period (see measures with or without a benchmark above).

The maximum payment adjustments for 2022 remain the same at +/- 9% and will be applied towards a clinician’s 2024 Medicare Part B payments for covered professional services.

Changes to Improvement Activities for 2022

Improvement Activities to be Removed New Improvement Activities
IA_ BE_13 Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms IA_AHE_8 – Create and Implement an Anti-Racism Plan (High)
IA_BE_17 – Use of tools to assist patient self-management IA_BMH_11 – Implementation of a Trauma-Informed Care (TIC) Approach to Clinical Practice (Medium)
IA_BE_18 – Provide peer-led support for self-management. IA_BMH_12 – Promoting Clinician Well-Being (High)
IA_BE_20 – Implementation of condition-specific chronic disease self-management support programs IA_ERP_4 – Implementation of a Personal Protective Equipment (PPE) Plan (Medium)

Redistributing Performance Category Weights for Small Practices 

The Final Rule updates the redistribution policies for small practices. When the Promoting Interoperability performance category is reweighted the following category weights will apply:

Quality will be weighted at 40%.

Cost will be weighted at 30%. 

Improvement Activities will be weighted at 30%. 

In cases where both the Cost and the Promoting Interoperability performance categories are reweighted the Quality and Improvement Activities categories will be equally weighted at 50%.