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MIPS: Tips for practices


As the Centers for Medicare & Medicaid Services (CMS) evolves its value-based reimbursement model, practices need to be aware of some of the tips for reporting in 2022.

Performance Thresholds
Eligible clinicians and practices must meet the threshold of 75 total Merit-based Incentive Payment System (MIPS) points to avoid penalty, and a potential negative adjustment. The points will be awarded in four categories: Quality (30%), Cost (30% - coming from claims data), Promoting Interoperability (25%), and Improvement Activities (15%).

The threshold to earn Exceptional Performer status was increased to 89 total MIPS points. The 2022 Performance Year/2024 Payment year is the last year that CMS will have an Exceptional Performer Payment Adjustment status.

Promoting Interoperability – 2022 Public Health Reporting
Practices are required to report on two options under Public Health Reporting (although some exclusions are available). The measures are the Immunization Registry Reporting where practices must register or be in active engagement with a public health agency to submit and receive immunization data or qualify for an exclusion; and Electronic Case Reporting (eCR) where practices work with a public health agency to electronically submit case reporting of reportable conditions. There is an additional exclusion for eCR if your EHR is not yet certified to meet those requirements for reporting year 2022. It is suggested that practices reach out to their vendor to get their status in the process.

Recommendations to Prepare for 2023

  1. Review your 2021 MIPS Feedback. The final feedback and payment adjustments will be available in August.
  2. Review your Patient Level Cost Details. The Cost Category patient level details will also become available in August. Set time aside to review this data and ensure your providers and practice are on track.
  3. Identify your Current Gaps. Armed with data from the feedback and from your current reports, you can be proactive for 2023 by implementing changes in workflows or making process improvements.

The Quality Reporting Engagement Group and the Business Analytics (InfoDive) team are preparing to discuss the 2023 Proposed Rule for MIPS on August 9. They will discuss any of the proposed changes that could impact your practice, including proposed changes to performance measures. To learn how you can partner with the team for your submissions, contact