In the 2022 Quality Payment Program (QPP) final rule, the Centers for Medicare and Medicaid Services (CMS) made a change to a longstanding policy that has complicated MIPS scores for clinicians in groups that have claims Quality reporters.
In 2019, CMS began restricting claims-based Quality category reporting to small practices and began automatically calculating a group MIPS score for TINs in which any clinician attached quality data codes (QDCs) to their claims. Because of this policy, groups that accidentally included QDCs on their claims or in which even one clinician reported a QDC, were assigned a group MIPS score by CMS, regardless of whether or not they intended to report at the group level. Any clinician in these groups who is only MIPS eligible at the group level (and not the individual level) will only have a group score for that performance year.
As a consequence, groups that were not intending to group report had low group scores assigned to those clinicians. In addition, because these clinicians are not eligible at the individual level, they have not been eligible for the automatic MIPS COVID hardships. This combination often caused these clinicians to be inappropriately penalized in the payment year.
New CMS Policy for 2022
To remedy this issue, CMS finalized a new policy for calculating a MIPS score for claims-based Quality reporters. Starting with the 2022 MIPS performance year, small practices will need to submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.
To break this down, in order to signal intent to group report, a group will need to submit data as a group to the Improvement Activities category, the Promoting Interoperability performance category, or to the Quality performance category via another submission mechanism as a group (for example, a group that submits MIPS CQMs in addition to Medicare Part B claims data).
What to Do if You're Claims Reporting in 2021, But Not Group Reporting
Make sure that you apply for and receive a 2021 extreme and uncontrollable circumstances (EUC) hardship for all MIPS performance categories at the group level or the clinicians in your group who are only MIPS eligible at the group level will likely receive a payment penalty in 2023.
- Share this information with your practice colleagues.
- If any of your clinicians reported QDCs in 2021 but you do not intend to group report, make sure to submit a 2021 EUC application for all categories at the group level.
- Review our Top 2022 Final MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.
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