Provide Feedback on Proposed Changes to the Quality Payment Program by September 13

The Centers for Medicare & Medicaid Services (CMS) issued its proposed policies for the 2022 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM). The deadline to submit comments on the proposed rule is September 13, 2021.

Highlights

The following are some of the key QPP policies that have been proposed in the NPRM:

  • MIPS Value Pathways (MVPs) begin in 2023 with 7 options for the first year
  • The CMS Web Interface extends as a collection type and submission type for quality measure reporting into the 2022 and 2023 performance years for Shared Savings Program Accountable Care Organizations (ACOs) (for other ACOs and registered groups and virtual groups the CMS Web Interface continues for the 2022 performance period only)
  • Updates to cost measures and improvement activities inventory
  • Revisions to Promoting Interoperability performance category reporting requirements

CMS is also seeking comment on a variety of potential changes in the NPRM, including:

  • Traditional MIPS sunsets after the end of the 2027 performance and data submission periods;
  • The development of new cost measures by stakeholders;
  • The appropriate number of procedures done or conditions treated at the facility types for which CMS is proposing to add affiliation; and
  • The types of utilization data that could be added to Care Compare to inform patients’ healthcare decisions.

Submit a Formal Comment by September 13

You must officially submit your comments in one of the following ways:

  • Electronically, through regulations.gov
  • Regular mail
  • Express or overnight mail
  • Hand or courier

Electronic comments are due no later than 11:59 p.m. ET on September 13, 2021 and mailed comments must be received by 5:00 p.m. ET, September 13, 2021.

For More Information

Learn more about the 2022 PFS NPRM and the Quality Payment Program proposals by reviewing the following resources:

  • 2022 QPP Proposed Rule Resources:
    • Overview Fact Sheet – Offers an overview of QPP’s proposed policies for 2022
    • Comparison Table – Compares 2022 NPRM proposals to the current policies in 2021
    • MVPs Proposals Table – Provides an overview of the proposed policies in the 2022 NPRM related to MVPs
  • MVP Transition Timeline for Comment Solicitation – Provides a visual display of a timeline for transitioning from traditional MIPS to MIPS Value Pathways (MVPs) that CMS is seeking comment on in the 2022 PFS proposed rule.

Questions

Contact the Quality Payment Program at 1-866-288-8292 by e-mail at: qpp@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours—before 10 a.m. and after 2 p.m. Eastern Time (ET). Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
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