A review and update for the Centers for Medicare and Medicaid Services (CMS) Merit-based Incentive Payment System (MIPS) by Barbara Rubel, SVP Marketing and Client Services, and a past president of the Radiology Business Management Association (RBMA), and Claudia Murray, director of quality payment programs Advanced BI, LLC, and senior vice president of regulatory affairs, and a board member of the Radiology Coding Certification Board (RCCB). 

The speakers presented this update originally at the RBMA 2022 annual meeting in April. 

MIPS is part of the Quality Payment Program created under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The bipartisan legislation was signed into law in 2015. It is designed to give financial and limited technical support to develop, improve, update or expand measures to use in the Quality Payment Program.

The goal of the program is to move CMS payments from a fee-for-service provided model to a value-based care system. This is an effort to both improve patient care and while trying to reduce overall healthcare costs and streamline the health system. MIPS entered its sixth performance year in 2022. 

Rubel and Murray explain how the program requirements have changed for the performance year 2022 and the changes in the pathways for achieving maximum success as defined by positive payment adjustments. They explain how to avoid negative payment adjustments and the consequences of failure. 

"Payment penalties will be harder to avoid in 2022 and 2023 and going forward, and this is because the radiology measures are being topped out," Rubel explained. "They are being devalued and they are being eliminated. A Big change this year is that all the bonus points for  high priority, outcome and end-to-end electronic reporting have been eliminated." 

An important take away is a glimpse at the program's future, what changes are expected, and if it will continue in its current form in the coming years. They explained that CMS’ introduction of the “MIPS value pathways” shows the agency’s desire to streamline MIPS. They said this initiative was been delayed by the COVID pandemic. CMS’s goal is to compare clinicians across common measure sets and to eliminate variability, both of which are currently very difficult under MIPS, the speakers said. They are also analyzing the success or failure of accountable care organizations and explain their relevance to radiology. 

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