2022 MIPS Step-by-Step Guide

This guide provides a high-level overview and examples of calculations for the Merit-Based Incentive Payment System (MIPS) performance categories of Quality (30 final MIPS points), Promoting Interoperability (25 final MIPS points), Improvement Activities (15 final MIPS points), and Cost (30 final MIPS points). The Cost category does not require data submission and is scored through claims submitted to Medicare. Below are details on calculating, collecting, and reporting each MIPS performance category with links to additional information. Calculating performance category points will vary on the participation level and collection type chosen by the physician. For more specific details, visit QPP’s Resource Library and search for “2022 PY Traditional MIPS scoring guide”.

 

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Source: QPP 2022 MIPS Overview Quick Start Guide

A maximum of 100 final MIPS score can be earned by achieving the full points in each category.



Using a composite performance score, eligible clinicians (ECs) may receive a payment bonus, a payment penalty or no payment adjustment. Eligible Clinicians (EC) will need to earn enough points in each category to achieve a total MIPS score greater than or equal to 75 points to avoid a 9% payment reduction/penalty in their 2024 Part B reimbursements. Any MIPS score over 75 points could result in incentive payment by increasing their 2024 Part B reimbursements. The percentage increase available is dependent on several scaling factors (not to exceed 3.0) to ensure that the adjustments are budget neutral. Exceptional Performance incentives are also available for those who outperform other ECs that participated in MIPS for the same performance year. The 2022 exceptional performance threshold is set at 89 final MIPS points. 2022 will be the last performance year for the exceptional performance threshold. For more information about the MIPS program and steps on getting started please review our MIPS page.

2022 PY and 2024 Payment Adjustments


Quality Step-by-Step Guide

The Quality category accounts for 30 final MIPS points out of the possible 100 final MIPS score. This category requires data reporting for a full year (Jan. 1 to Dec. 31, 2022) on at least 6 selected measures. Each measure is worth up to 10 points (allowing for a maximum of 60 available points), and depending on performance physicians/practices will receive between 3 and 10 points per measure. New measures added to PY 2022 will have a 7 point scoring floor. Beginning PY 2022, there are no bonus points for reporting additional outcome and high-priority measures beyond the ones required, and no bonus points for end-to-end electronic reporting. Up to 10 additional percentage points are available based on a physicians’ improvement in their quality performance category from the previous year. If CMS can’t compare data between 2 performance periods, or there is no improvement, the improvement score will be 0%. The improvement score can’t be negative.

Source: QPP 2021 Traditional MIPS Scoring Guide
Note: 2022 PY follows same scoring guide

Example (does not consider any possible bonus points or improvement scoring practices could achieve such as the small practice bonus and others offered within MIPS):

Dr. Smith reported on 6 quality measures. On three of her measures, she received the full 10 measure points, but on the other three she was only able to achieve 8 measure points each. Since three of the measures submitted were new measures, the 7-point scoring floor was enforced, meaning new measures for the 2022 PY (first performance period) will earn 7-10 points (if a performance benchmark can be created, and data completeness and case minimum criteria is met).

(10 points x 3 measures) + (8 points x 3 measures) = 54 category points
54 category points ÷ 60 category measure points possible = .90 or 90%

Because Dr. Smith achieved 90% of her category measure points, she can apply 90% of the 30 final MIPS Quality points available to her final MIPS score:

30 final MIPS Quality points x .90 or 90% = 27 final MIPS points

Dr. Smith’s FINAL MIPS Quality score is 27 points, which will be counted towards her final MIPS score. This point total is less than the 75 MIPS points benchmark, therefore Dr. Smith will have to participate in other categories to potentially receive an incentive payment for achieving > 75 MIPS points.


Promoting Interoperability (PI) Step-by-Step Guide

The PI category accounts for 25 final MIPS points out of the possible 100 final MIPS score. This category requires a performance period of at least 90 consecutive days in the performance year. Revisions to the Public Health and Clinical Data Exchange objective requirements were made for 2022 including an additional requirement, an added exclusion to certain measures, and optional reporting measures for up to 15 bonus points. Total available category points are 115 with a capped category score of 100 possible measure points (no less than 100 points in the denominator when scored).

For 2022, the PI category requires the use of an Electronic Health Record (EHR) that meets the 2015 Edition certification criteria, 2015 Edition Cures Update certification criteria, or a combination of both. Participants must submit collected data for certain required measures (5 to 6 required measures) from each of the 4 objectives measures (unless an exclusion is claimed).

In addition to submitting measures, clinicians must provide their EHR’s CMS Identification Code from the Certified Health IT Product List (CHPL) and submit a ”yes” to:

  • The Prevention of Information Blocking Attestation,
  • The ONC Direct Review Attestation,
  • The security risk analysis measure, and;
  • The SAGER Guides measure

 

 

Source: QPP 2021 Traditional MIPS Scoring Guide
Note: 2022 PY follows same scoring guide

Example:

Dr. Smith’s EHR is 2015 certified. After completing all the required PI measures Dr. Smith achieves 80 category points (we use 100 category points possible for this calculation rather than the total possible of 115 because this category is capped at 100 points). 

80 category points ÷ 100 category points possible = .8 or 80%

Because Dr. Smith achieved 80% of her category points, she can apply 80% of the 25 final MIPS PI points available to her final MIPS score.

25 final MIPS ACI points x .80 or 80% = 20 final MIPS points

Dr. Smith’s final MIPS PI score is 20 points, which will be counted towards her final MIPS score. This point total does not meet the 75 MIPS points benchmark; therefore Dr. Smith need to submit data for another category along with the PI category to reach the 75-point benchmark and avoid a 9% penalty on her 2024 Medicare payments.

 

You will receive 0 points in the Promoting Interoperability performance category if you fail to submit a required attestation, report nothing in the numerator on a required measure, or claim an exclusion for a required measure.


Improvement Activities (IA) Step-by-Step Guide

The IA category accounts for 15 final MIPS points out of the possible 100 final MIPS score. This category requires each activity selected to be implemented within your practice for at least 90 consecutive days during 2022. This category is attestation based, which means only a “yes” or “no” statement is required for each activity completed when the reporting period begins. No documentation is required to be submitted but it is important to keep record of the activity completion in case of an audit by CMS.

There are two levels of activities medium-weighted and high-weighted activities. Small practices (15 clinicians or fewer) can complete 2 high-weighted activity (each worth 20 category points) or 4 medium-weighted activities (each worth 10 category points), or 2 medium and 1 high weighted activities to achieve a full 40 out of 40 maximum category points, resulting in receiving the full 15 final MIPS points towards their final MIPS score.


Source: QPP 2021 Traditional MIPS Scoring Guide
Note: 2022 PY follows same scoring guide

Example:

Dr. Smith works in a practice of 10 clinicians (considered a small practice). The practice has selected 2 medium weighted activities to complete for 2022 (activities completed by a practice can be attested to by an individual or group).

(1 medium activity x 20 points) + (1 medium activity x 20 points) = 40 category points

40 category points ÷ 40 category points possible = 1 or 100%

Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 15 final MIPS IA points available to her final MIPS score:

15 final MIPS IA points available x 1 = 15 points

Dr. Smith’s final MIPS IA score is 15 points, which will be counted towards her final MIPS score.

  

Larger practices (greater than 15 clinicians) will be required to do double the number of activities to achieve a full 40 category points (following the standard scoring) to obtain their 15 final MIPS points. Medium weighted activities for large practices are worth 10 category points each (requiring 4 be completed to achieve 40 points) and high weighted activities are worth 20 category points (requiring 2 be completed to achieve 40 points). A combination of high and medium weighted activities may be completed to achieve a full category score as long as a total of 40 category points are achieved. However, if you submit additional activities, you cannot earn more than 100% in the performance category.


Cost Point Calculation

Cost is not manually submitted and is measured behind the scenes at CMS using claims data. There are 25 total cost measures available for the 2022 performance period. Total number of category points available in the Cost category is determined by which measures apply to your practice, therefore, the maximum category points with all included measures (if you exceed the minimum case volume for all measures) is 250 points (25 total cost measures, up to 10 points each measure). Improvement Scoring will be calculated in the cost performance category beginning the 2022 performance year and will apply if CMS can compare data between 2 performance periods.

Source: QPP 2021 Traditional MIPS Scoring Guide
Note: 2022 PY follows same scoring guide


Example:

Dr. Smith was informed by CMS that she was only eligible for 8 out of the 25 available measures, therefore, she will be scored only on the measures that met the case minimum. She received 10 points on all 8 measures she was scored on.

Total Available Measure Achievement Points = (8 measures x 10 measure points)
                                                                   = 80 category points possible

          
Total Achievement Points Earned for Scored Measures = 80 Category points scored / 80 Category points possible
                       = 1 or 100%

Although there are 25 total measures, Dr. Smith was only eligible for 8 measures so she will only be scored on those that she is eligible for, bringing her total max category points to 80 rather than 100.

Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 30 final MIPS Cost points available to her final MIPS score:

30 final MIPS Cost points available x 1 = 30 points


Total points and final MIPS score for Dr. Smith
With a final MIPS score of 92 out of a possible 100, Dr. Smith will avoid a 9% penalty to her 2024 Medicare Part B payments and will most likely receive incentive payments as well. This also places Dr. Smith above the exceptional threshold mark (89 total final MIPS points), which makes Dr. Smith eligible for additional payment for exceptional performance.

Final MIPS Quality Score = 27
                    +
         Final MIPS PI Score = 20
                    +
    Final MIPS IA Score = 15
                    +
    Final MIPS Cost Score = 30

 = Total Final MIPS Score = 92