MIPS 2022—What’s New With Your MIPS Final Score and Payment Adjustment

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.

Your 2022 MIPS final score (0-100 points) impacts 2024 reimbursement. In 2024, your payments for Medicare Part B services will be adjusted up or down based on your 2022 MIPS final score (see “Bonuses and Penalties”). As in past years, this score can range from 0 to 100 points and is based on up to four performance category scores plus a complex patient bonus.

Quality’s contribution is down, cost’s is up. When CMS calculates your 2022 MIPS final score, the default weights of your performance category scores are as follows:

• Quality’s default weight is 30% (down from 40% in 2021), meaning that it contributes up to 30 points to your MIPS final score.
• Promoting interoperability (PI), which is MIPS’ electronic health record (EHR)–based performance category, has a default weight of 25% (same as in 2021).
• Improvement activities’ default weight is 15% (same as in 2021).
• Cost’s default weight is 30% (up from 20% in 2021).

As in previous years, you can earn bonus points for medical complexity. One early concern about scoring MIPS performance was that clinicians who look after complex patients may be at a disadvantage. In 2018, CMS attempted to address this by introducing the com­plex patient bonus. This bonus score is determined by two indicators of med­ical complexity: 1) the average Hierar­chical Condition Category (HCC) risk score of your patients and 2) their “dual eligible” score, which is based on the proportion of your patients who are eli­gible for both Medicare and Medicaid.

The complex patient bonus will be more targeted than in the past. Start­ing in the 2022 performance year, you will be eligible for the complex patient bonus only if you have at least a median score for the HCC risk indicator and/ or the dual eligible indicator. CMS also has revised the formula for calculating the number of bonus points that you will get, with the goal of better reward­ing those who are delivering care to highly complex patients.

The complex patient bonus will be capped at 10 points. At the start of the 2020 and 2021 performance years, CMS said that the complex patient bonus would be capped at 5 points. However, this was then upped to 10 points be­cause of the COVID-19 public health emergency. For the 2022 performance year, CMS has said at the outset that it will cap the bonus at 10 points.

The thresholds for avoiding a penalty and for earning bonuses are higher than in 2021. For the 2022 performance year, CMS has raised the bar on three key thresholds:

• You need a score of at least 18.76 points to avoid the maximum –9% pen­alty (up from 15.01 points in 2021);
• there is a 75-point threshold to get a neutral adjustment (up from 60 points); and
• there is an 89-point threshold for getting an exceptional performance bonus (up from 85 points).

Last call for the exceptional per­formance bonus. The MIPS program features two bonus payments:

• You can earn an initial bonus if your MIPS final score exceeds the 75-point performance threshold. This bonus is budget neutral, with bonuses being funded by penalties that are imposed on those whose MIPS final score is less than 75 points.
• You also can earn an exceptional performance bonus if you meet or exceed the additional performance threshold, which has been set at 89 points for 2022. This second bonus is funded by an additional $500 million per year that has been set aside for the first six years of the MIPS program. The 2022 performance year is the last opportunity to earn the exceptional performance bonus, with a correspond­ing increase to your reimbursement during the 2024 payment year.

Table: Bonuses and Penalties

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

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