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Top Three Takeaways from the 2022 Quality Payment Program Proposed Rule

The 2022 Quality Payment Program (QPP) Proposed Rule, which CMS released on July 13th, includes changes to the MIPS program that will make avoiding a penalty difficult, along with updates to the controversial APM Performance Pathway (APP) reporting requirements, and more insight into the MVP program.  Following are three key takeaways from the Proposed Rule to consider as you evaluate how changes could impact your organization.

1. Difficulty Avoiding Penalties Increases

Avoiding a penalty in MIPS will become a lot harder for three reasons—the Performance Threshold will be increased to 75 points, most bonus points will be removed, and the Cost category will increase to 30 points of the total score.

What this means:

  • Per the MACRA legislation, for Performance Year (PY) 2022, CMS must set the Performance Threshold (PT) to the mean of a previous performance period’s data which has resulted in the PT becoming 75 points for PY 2020. This will be a challenge, especially combined with the next two changes.
  • CMS is proposing the elimination of the End-to-End Electronic Submission and High Priority measure bonus points in the Quality category. Along with this, the number of clinicians that will receive a Complex Patient Bonus will be cut in half to better recognize the challenges faced by clinicians with high risk (HCC) and dual eligible patient populations.
  • The Cost category, which is calculated by CMS using claims data, is increasing to 30 points per the MACRA legislation requirements. The Cost category is especially difficult because CMS does not provide any performance feedback on those measures during the performance year, so clinicians are ‘flying blind’.

2. Extended Web Interface Submission

In the 2021 Final Rule, CMS announced that the Web Interface submission method would be sunsetted after PY 2021 and MSSP ACOs would be required to submit eCQMs or CQMs for three measures.

What this means:
This approach, and the aggressive timeline, received significant pushback by ACO organizations— including the National Association of ACOs (NAACOs).  In the 2022 Proposed Rule, CMS has recognized these concerns and is extending the Web Interface submission method through PY 2023.  But, CMS is also proposing that for PY 2023 organizations must be able to submit one eCQM or CQM in a pay for reporting requirement in addition to the traditional Web Interface measures.  This will force ACOs to have data integration across the ACO as eCQMs or CQMs must be calculated, using patient level data, at the ACO level.  The cost to implement this infrastructure is a major concern of NAACOs.  It will be interesting to see what additional changes, if any, will be in the final rule.

3. MVPs Delayed Until 2023

MIPS Value Pathways (MVPs) are being delayed until 2023 and will initially launch with 7 available MVPs.

What this means:
Participation will be voluntary for PYs 2023 and 2024, with a proposed sunset of Traditional MIPS in 2028.  Hand in hand with the release of MVPs will come a new reporting level, Subgroup reporting.  Subgroup reporting has been discussed as a necessity to truly assess performance in multi-specialty TINs since the launch of MIPS in 2017.  Subgroup reporting will only be available for MVPs in PY 2023, but all HCIT vendors that offer MIPS services are required to provide MVP and Subgroup submission functionality for the 2023 performance year—which is likely an aggressive timeline for most vendors.  Between the ongoing pandemic and the technical changes that need to be made by vendors and CMS to support MVPs and Subgroup reporting, I am not sure we will see much more than a pilot program for MVPs in 2023, if they are not completely delayed until 2024.

One thing that was not addressed in the Proposed Rule documentation was clarity around CMS’s thinking regarding another COVID-related Hardship Exception for PY 2022.  As the pandemic continues to unfold with the new Delta variant during the second half of this year, it is harder than ever to predict how much of the Proposed Rule will change between now and when the 2022 Final Rule is released in November or December.

7 Proposed MVPs for 2023

  • Rheumatology
  • Stroke Care and Prevention
  • Heart Disease
  • Chronic Disease Management
  • Emergency Medicine
  • Lower Extremity Joint Repair
  • Anesthesia

To learn more about the 2022 QPP Proposed Rule, watch the ABCs of VBC webinar recording Understanding the Proposed 2022 Quality Payment Program Rule where Azara’s Matt Fusan, SVP Product and Erica Arias, Director of Client Success dissect the proposed changes and the impact those changes could have to healthcare providers.

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