2022 Quality Payment Program (QPP) Proposed Rule

CMS released its 2022 Quality Payment Program (QPP) Proposed Rule. The proposed rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models, and other features of the QPP during the 2022 performance year.

For 2022:

• CMS is proposing a performance threshold of 75 points. Scoring 75 points out of 100 total points will allow groups and individuals to avoid a negative payment adjustment. Earning 89 points will result in an exceptional performance bonus.
• The Quality performance category will be weighted at 30% and the cost performance category will be weighted at 30%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
• QID044 (Coronary Artery Bypass Graft [CABG]: Preoperative Beta Blocker in Patients with Isolated CABG Surgery) will be retired and removed from the program.
• CMS has proposed an end to “traditional” MIPS after calendar year 2027 with a mandatory move to MIPS Value Pathway (MVP) reporting at the beginning of calendar year 2028.

ASA leaders and staff will review the rule and submit comments by the Sept 13, 2021, deadline. Finalized provisions will become effective January 1, 2022.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at qra@asahq.org.

2020 MIPS Performance Year - Cost Category

In advance of release of the MIPS final scores CMS announced that they reweighted the cost performance category from 15% to 0% for the 2020 performance period for all MIPS eligible clinicians regardless of participation as an individual, group, virtual group, or APM Entity. The 15% cost performance category weight will be redistributed to other performance categories.

Clinicians do not need to take any action as a result of this update. More information can be found on the Quality Payment Program Website.

2021 Improvement Activities

Has your practice selected Improvement Activities for the 2021 MIPS performance year? The top five Improvement Activities reported to NACOR for 2020 were:

• PSPA_1: Participation in an AHRQ-listed patient safety organization.
• PSPA_19: Implementation of formal quality improvement methods, practice changes or other practice improvement processes.
• PSPA_20: Leadership engagement in regular guidance and demonstrated commitment for implementing practice improvement changes.
• PSPA_16: Use of decision support and standardized treatment protocols.
• BE_13: Regularly assess the patient experience of care through surveys, advisory councils, and/or other mechanisms.

As a reminder, groups can attest to an activity when at least 50% of the clinicians in the group perform the same activity during any continuous 90-day period (or as specified in the activity description) in the same performance year.

ASA has developed nine (9) downloadable documentation guidance templates for commonly reported improvement activities for anesthesiologists and pain medicine physicians. Please note, these templates have been drafted using recommended documentation from the Centers for Medicare and Medicaid Services (CMS) but have not been validated or approved by CMS. It is recommended that practices keep all documentation for at least six years.

AQI Office Hours - new format coming in August

Starting in August, AQI and QRA staff will no longer conduct live monthly office hours. We will continue to offer monthly presentations which will be posted on the AQI website for NACOR participants to review at their convenience. Two live sessions will tentatively be planned: for November to review the CMS Final Rule, and in February to review program and measure changes for the new MIPS performance year.

Please continue to send questions to askaqi@asahq.org