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  • MIPS 2022—Small Practices: New Policies for Reweighting Promoting Interoperability

    Excerpted from “MIPS—What’s New for 2022, Part 1: Scoring, Bonuses, and Penalties” (EyeNet, January 2022). Also see, EyeNet’s MIPS Manual 2022: A Primer and Reference.

    Background: Performance categories can be reweighted. As in previous performance years, if CMS determines that you shouldn’t be scored on a performance category, it will reduce that category’s weight to zero and increase the weight of one or more of the other performance categories accordingly when calculating your MIPS final score.

    This can happen if an “extreme and uncontrollable circumstances” exclusion applies, if a PI exception applies, or if you don’t meet the case minimum for any of the cost measures.

    For example, if CMS can’t score you on any cost measures, cost’s weight in your MIPS final score will be reduced from 30% to 0%, quality’s weight will be increased from 30% to 55%, and PI’s weight will be increased from 25% to 30%. In some circumstances, you need to submit an application to have a performance category reweighted; in others, the reweighting may happen automatically. 

    For PI, the small practice exception is now automatic. In 2018, CMS introduced a PI exception for small practices, which CMS defines as practices with 15 or fewer “eligible clinicians.” Initially, MIPS participants had to apply for this exception. However, starting with the 2022 performance year, if you are in a small practice and you do no PI reporting, CMS will automatically apply the small practice PI exception. Warning: If you do any PI reporting at all, CMS will score you on any PI data that you submit and will factor your PI performance category score into your MIPS final score.

    New reweighting policy for small practices. In 2022, there are two scenarios where the reweighting policy depends on whether your practice is small or large:

    • When PI alone is reweighted to zero
    • When PI and cost are reweighted to zero

    In both cases, if you are in a large practice the adjusted weight(s) will be moved to your quality score. If you are in a small practice, the weight(s) will be split between your quality score and your improvement activities score (see “Reweighting PI—Small Versus Large Practice”). 

    What’s the rationale behind the new reweighting policies? CMS has acknowledged that small practices tend to have more limited infrastructure and resources than larger practices. When reapportioning PI’s weight for a small practice, the agency has said that it should “put more emphasis on a performance category that poses a reduced reporting burden such as the improvement activities performance category.”

    How do the new reweighting policies benefit small practices? It is much more feasible to obtain a high score for the improvement activities performance category than it is for quality. Indeed, a small practice can score 100% for improvement activities by successfully performing, and reporting, one high- or two-medium weighted activities..

    Reweighting PI—Small Versus Large Practice

    There are two scenarios where the reweighting of your MIPS final score will depend on whether your practice is classified as small or large.
    Reweighting Scenario Practice Size Weighting in MIPS Final Score
    Quality PI IA Cost
    No reweighting Small or large Weight: 30% 25% 15% 30%
    Points: 0-30 0-25 0-15 0-30
    No PI Small Weight: 40% 0% 30% 30%
    Points: 0-40 0 0-30 0-30
    Large Weight: 55% 0% 15% 30%
    Points: 0-55 0 0-15 0-30
    No PI and no cost Small Weight: 50% 0% 50% 0%
    Points: 0-50 0 0-50 0
    Large Weight: 85% 0% 15% 0%
    Points: 0-85 0 0-15 0
    PI = Promoting interoperability. IA = Improvement activities.

    Previous: MIPS 2022—What’s New With Your MIPS Final Score and Payment Adjustments

    Next: MIPS 2022—What’s New With Quality

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