Three Steps to Radiology MIPS Success
May 26, 2022
There are three critical steps to maximizing Medicare reimbursement by optimizing your MIPS score. But first, radiologists need to understand the 2022 MIPS changes and requirements that must be met to avoid the negative 9% payment adjustment for noncompliance and achieve a bonus.
Physicians have two tracks to choose from under the CMS Quality Payment Program: MIPS and Advanced Alternative Payment Model (APM). There are no 2022 APM-related changes impacting radiology, so this article will focus on the changes and requirements impacting the four performance categories under traditional MIPS.
Quality
Cost
Promoting
Interoperability
Improvement Activities
Quality Performance Category
In 2022, under the traditional MIPS track, quality is weighted at 30% compared to 40% in 2021.
CMS has implemented the following changes for quality measures, including:
- Remove Bonus Points — Removing bonus points awarded for reporting additional outcomes or high priority measures beyond the one required and end-to-end electronic reporting.
- Increase New Measure Score — For new measures, established a 7-point floor for the first performance period and a 5-point floor for the second performance period. Typically, new measures are awarded 3 points.
- Measures Removed — Two commonly reported radiology quality measures were deleted, measure #195: Stenosis Measurement in Carotid Imaging Reports and measure #225: Reminder System for Screening Mammograms.
CMS will maintain the Quality measure data completeness threshold at 70% for the 2022 and 2023 performance periods. Under this category, participants are scored on how well they met the performance of a measure. Radiologists need to understand the information which must be documented in the final report to meet the intended performance of a case and code a case performance met.
For more information on how to maximize your MIPS Quality score, review the
XiFin MIPS Radiology Quality Quick-Reference Guide.
Cost Performance Category
In 2022 cost and quality will be equally weighted. The weighting for the cost performance category increased to 30% from 20% in 2021. If CMS determines the available cost measure does not apply to a participant, the category will be automatically reweighted.
In 2022, five newly developed episode-based Cost measures were added.
- 2 Procedural measures: Melanoma Resection and Colon/Rectal Resection
- 1 Acute Inpatient measure: Sepsis
- 2 Chronic Condition measures: Diabetes and Asthma/Chronic Obstructive Pulmonary Disease [COPD]
The cost category assesses the overall cost of care provided to Medicare patients, focusing on the primary care they received. CMS will continue to utilize claims data to calculate cost measure performance, which means clinicians and groups don’t have to submit any data for this performance category.
Promoting Interoperability Performance Category
The weight for improvement activities remains unchanged at 25%. Beginning with the performance year 2022, CMS will apply automatic reweighting of this category for small practices with 15 or fewer physicians and clinical social workers.
For the Public Health and Clinical Data Exchange Objectives, CMS modified the reporting requirements and is only requiring participants to report on the following two measures unless an exclusion applies:
- Immunization Registry Reporting
- Electronic Case Reporting
For the 2022 performance period the Public Health Registry Reporting, Clinical Data Registry Reporting, and Syndromic Surveillance Reporting are optional measures. Reporting more than one of these optional measures will not result in more than five bonus points.
A new required measure Safety Assurance Factors for EHR Resilience Guides (SAFER Guides), was also added. Participants must attest to conducting an annual assessment of the High Priority Guide of the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides).
The three requirements under the promoting interoperability category are:
- Utilize an Electronic Health Record that meets the 2015 criteria
- Submit collected data for measures from each of the 4 objectives for the same 90 continuous days
- Attest yes to the Prevention of Information Blocking Attestation, ONC Direct Review Attestation, security risk analysis measure, and SAFER Guides Measure
Improvement Activities Changes
In 2022, the weight for improvement activities will remain unchanged at 15%. Seven new improvement activities were added in 2022.
- Create and Implement an Anti-Racism Plan (IA_AHE_8)
- Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols (IA_AHE_9)
- Implementation of a Trauma-Informed Care (TIC) Approach to Clinical Practice (IA_BMH_11)
- Promoting Clinician Well-Being (IA_BMH_12)
- Implementation of a Personal Protective Equipment (PPE) Plan (IA_ERP_4)
- Implementation of a Laboratory Preparedness Plan (IA_ERP_5)
- Application of CDC’s Training for Healthcare Providers on Lyme Disease (IA_PSPA_33)
Under this category, participants must attest to completing a combination of high and medium-weighted activities, totaling 40 points, for 90 days.
Performance and Reweighting Changes
CMS weights each MIPS category, when CMS determines a category is not applicable to a participant, then the categories are reweighted. The 2022 MIPS category weights based on practice size are listed below:
The points received in the four weighted performance categories make up a participant’s MIPS final score. How your final score compares to the performance threshold set by CMS each year will determine whether a penalty or bonus is received.
The performance threshold increased from 60 points in 2021 to 75 in 2022. In 2022, participants who score below 75 points will receive a 9% negative payment adjustment in 2024. Participants who score above 75 points will receive a positive payment adjustment. CMS also increased the exceptional Performance Threshold from 85 points in 2021 to 89 in 2022. 2022 is the last year for an additional MIPS adjustment for exceptional performance.
This is a budget-neutral program, which means the bonus paid under this program must be funded by the penalties applied. In 2020, the highest positive payment adjustment received was 1.87% for a score of 100 points.
Optimizing Your MIPS Score
To optimize your MIPS score, radiologists need to focus on the following three key steps:
- Quality: Ensure the required information is documented in the final report to maximize the number of cases coded performance met and minimize the number of cases coded performance not met, which will negatively impact your score.
- Improvement Activities: Attest to performing a combination of improvement activities equaling 40 points for 90 continuous days.
- Promote Interoperability: For larger practices with over 15 physicians, utilize an EHR that meets the 2015 criteria, submit collected data from each of the four objective measures for the same 90 continuous days, and complete attestation requirements.
MIPS participating clinicians should be evaluating their MIPS scores monthly. Tracking your MIPS score monthly allows clinicians to make informed decisions on maximizing performance in each category or take steps to avoid a penalty.
Recommended Resources:
Access the printable guide, which details the required report documentation for the most common radiology MIPS Quality measures.
Review the 2022 Quality Payment Program Final Rule Resources. Located on the CMS QPP Resource webpage, the link to the 2022 Program includes a fact sheet, comparison tables, and FAQs.
Contact us today to discuss your RCM needs.