CMS Nixes MIPS Facility-Based Scoring for 2022 Performance Year

Facility-based scoring in the Merit-Based Incentive Payment System (MIPS) will not be available for the 2022 performance year after recent changes to the Hospital Value-Based Purchasing (VBP) Program, CMS recently announced.

In an email on Friday, CMS said that it will not offer MIPS facility-based scoring because the Fiscal Year (FY) 2023 Inpatient Prospective Payment System (IPPS)/Long-Term Care Hospital Prospective Payment System (LTCH PPS) Final Rule finalized the suppression of several measures in the Hospital VBP Program. The agency finalized the changes to the program because of the effect COVID-19 has continued to have on measure performance.

That final policy, however, will impact MIPS facility-based scoring, CMS explained.

“We believe that calculating a total performance score in the Hospital VBP Program for hospitals using only data from the remaining measures wouldn’t result in a fair national comparison,” the agency stated in the email. “As a result, we aren’t calculating an FY 2023 total performance score under the Hospital VBP Program for any hospital.”

Under MIPS, CMS uses the total performance score from the Hospital VBP Program to determine MIPS facility-based scores for clinicians and groups working in hospitals and other healthcare settings. The agency takes the score for MIPS quality and cost performance categories.

CMS would have used the FY 2023 total performance score from the Hospital VBP Program to calculate scores for the 2022 MIPS performance year.

Eligible facility-based clinicians will still need to report measure performance to MIPS for the 2022 performance year. CMS said that the clinicians and groups will need to gather and submit MIPS quality measures in order to get a score other than zero for the quality performance category.

The clinicians and groups will need to submit six quality measures, if available and applicable, according to the 2022 Facility-Based Quick Start Guide.

However, eligible facility-based clinicians and groups will not have to collect or submit data for the MIPS cost performance category.

CMS noted that if a facility-based clinician or group does not meet the case minimum for any cost measures, then the performance category will be reweighted to 0 percent and the original weight will be redistributed to other MIPS performance categories.

Facility-based clinicians and groups can also request performance category reweighting if they do not have available and applicable measures. They can do this by submitting a 2022 MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application. Applicants must cite COVID-19 as the triggering event since CMS finalized Hospital VBP Program measure suppression because of the virus’ effect on performance.

MIPS facility-based scoring enables eligible clinicians to use their hospital’s Hospital VBP Program score for MIPS. CMS takes the hospital’s total performance score and compares it to all other facilities to place hospitals into percentiles.

The agency then takes a look at unweighted MIPS quality and cost performance category percentile scores for MIPS participants and identifies which 2022 MIPS quality (percentile) score and cost (percentile) score maps to the percentile associated with the Hospital VBP Program score. The mapped MIPS quality percentile score is multiplied by the quality performance category weight to calculate quality performance category points for a MIPS clinician’s or group’s final score.

Finally, CMS multiples the mapped MIPS cost percentile by the cost performance category weight to determine the cost performance category points.

In light of the FY 2023 IPPS/ LTCH PPS Final Rule, CMS said in the 2022 Facility-Based Quick Start Guide it cannot perform the mapping necessary to determine MIPS facility-based scores.