MIPS and the 2022 Final Rule: Key Takeaways

Once you spend enough time learning about Medicare’s Merit-Based Incentive Payment System (MIPS), it’s almost guaranteed that you’ll develop a love-hate relationship with it. That is, you’ll love to hate it!

Bu dum tss. 

Okay, okay; I’ll admit that wasn’t a great joke. Let me start over. 

MIPS is a complicated Medicare program that is difficult to learn and participate in due to the annual rule changes that come courtesy of each year’s final rule. But even if rehab therapists would rather leave the regulatory program in the dust, some are mandated to participate—and others choose to participate in an effort to nab some of the financial incentives that are offered to high performers.

For those therapists, we like to provide as much clear-cut MIPS information as possible—love-hate relationship or no. So, consider this article your one-stop shop for 2022 MIPS information. Here’s what changes in the 2022 final rule—and here’s what didn’t.

Please note: This article is written for people who already have a passing familiarity with MIPS. If you need a quick rundown of the MIPS program (or a refresher course) check out this download instead.

Low-Volume Threshold

The 2022 low-volume threshold (i.e., the criteria that determines whether or not providers need to participate in the MIPS program) is staying the same. That means individual providers must meet all three of the following criteria during both determination periods in order to be mandated to report in MIPS: 

1. Providers must bill Medicare for more than $90,000 in Part B allowed charges; and
2. Providers must furnish care to more than 200 Medicare Part B beneficiaries; and
3. Providers must furnish more than 200 covered professional services under the Physician Fee Schedule.

(Not sure what determination periods or “covered professional services” are? Seriously, peep the download.)

Individuals, Groups, and Subgroups

When providers participate in MIPS, they can either submit data as an individual, a group, or a virtual group. As in previous years, only individuals can be mandated to report—groups and virtual groups cannot be required to participate in the program. (Though, of course, if you belong to a group that has elected to report for the 2022 performance year or you’ve joined a virtual group for 2022, then you must report in 2022. No take-backsies!)

The only change here is in regard to subgroups. CMS has declared that, beginning in the 2023 performance year, groups will be allowed to report in subgroups, defined as “a subset of a group which contains at least one MIPS eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician’s NPI.” 

What does that mean?

Essentially, CMS is allowing big multi-specialty practices (think POPTS) that are reporting as a group to split up by specialty, so each specialty subgroup can report information that’s actually relevant to their clinical treatment. So, instead of asking everyone in a POPTS to report on the same measures, the physicians can report on measures designed for physicians and the therapists can report on measures designed for therapists. 

Performance Thresholds

In 2022, the performance threshold (i.e., the score you need to meet or exceed in order to avoid a negative adjustment) is an overall 75 points. The exceptional performance threshold (i.e., the score you need to meet to gain an additional positive adjustment on top of your standard performance adjustment) is 89 points. CMS did reiterate, though, that the 2022 performance year will be the last year in which participants can earn the bonus. 

MIPS Participation Categories

PTs, OTs, and SLPs who participate in MIPS in 2022 will only submit data and receive scores for two of the four MIPS categories: Quality and Improvement Activities. For providers in large practices (i.e., those that have more than 15 providers billing under the same TIN), the Quality category will account for 85% of their total MIPS score, and the Improvement Activities category will account for 15%. For providers in small practices (i.e., those with 15 or fewer providers), the Quality and Improvement Activities categories will both individually account for 50% of their total MIPS score

Quality Measures

Let’s talk about the Quality category. In the 2022 performance year, rehab therapists will need to complete the Quality category, which requires reporting up to six quality measures (five process measures, and one outcomes measure).  

The long and the short of it is that the overall requirements for the Quality category won’t change in 2022. Each measure must be reported on 70% of all patients, regardless of payer, for the performance period—unless the MIPS participant is doing claims-based reporting. If that’s the case, then they only must report these measures on 70% of their Medicare Part B patients during the performance period.

And here’s a nugget of information that might interest specialty rehab therapists (and especially SLPs): “If fewer than six measures apply to the MIPS eligible clinician or group, CMS will adjust your denominator for the Quality category by 10 points for each measure that isn’t available.”

PT and OT Measures

If you’re wondering which Quality measures PTs and OTs can report, here’s a list of all the processes measures that appear in the PT/OT specialty set in 2022. 

• 050: Plan of Care for Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older
• 126: Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological Evaluation
• 127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear
• 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
• 130: Documentation of Current Medications in the Medical Record
• 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan
• 155: Falls: Plan of Care
• 181: Elder Maltreatment Screen and Follow-Up Plan
• 182: Functional Outcome Assessment
• 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
• 281: Dementia: Cognitive Assessment
• 283: Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
• 286: Dementia: Safety Concern Screening and Follow-Up for Patients with Dementia
• 288: Dementia: Education and Support of Caregivers for Patients with Dementia
• 318: Falls: Screening for Future Fall Risk

The outcomes measures in the specialty set (which are all owned by FOTO) are as follows: 

• 222: Functional Status Change for Patients with Elbow, Wrist or Hand Impairments
• 218: Functional Status Change for Patients with Hip Impairments
• 217: Functional Status Change for Patients with Knee Impairments
• 220: Functional Status Change for Patients with Low Back Impairments
• 219: Functional Status Change for Patients with Lower Leg, Foot or Ankle Impairments
• 478: Functional Status Change for Patients with Neck Impairments
• 221: Functional Status Change for Patients with Shoulder Impairments

SLP Measures

As for the SLP measure set, nothing is changing in 2022. See the SLP specialty set below:  

• 130: Documentation of Current Medications in the Medical Record
• 134: Preventative Care and Screening: Screening for Depression and Follow-Up Plan
• 181: Elder Maltreatment Screen and Follow-Up Plan
• 182: Functional Outcome Assessment
• 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention

Improvement Activities

As it has in previous years, CMS deleted some “duplicative” improvement activities. There are too many activities that rehab therapists could report to list out in this blog post, so instead, we’ll list out the deleted activities that rehab therapists commonly reported in previous performance years: 

• IA_BE_13: Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms.
• IA_BE_20: Implementation of condition-specific chronic disease self-management support programs.
• IA_BE_21: Improved practices that disseminate appropriate self-management materials.

MIPS Value Pathways

Alright, at this point of the blog post, you might be asking: What about MIPS Value Pathways (MVPs, for short)? Well, CMS will not roll out MVPs until 2023 at the earliest—and if they do become mandatory functions of the program, they will be optional to report until 2028. In other words, there’s a little time before rehab therapists need to think about them. 

MIPS might be a difficult program to get a handle on, but it certainly is possible—especially if you rely on help from other compliance experts. That said, you may still have some questions that you need answered. If you do feel free to drop ‘em below!