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  4. CMS Releases MIPS Payment Adjustments for 2022, Which Are Higher Than Previous Years

The Centers for Medicare & Medicaid Services (CMS) released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for the 2022 performance year, which determines whether a physician will receive a positive, neutral, or negative payment adjustment on Medicare services furnished in 2024. MIPS-eligible pathologists should view this information on the Quality Payment Program (QPP) website.

The CAP appreciates that the positive payment adjustments are increasing, but the 2022 MIPS scoring numbers are higher because they include a bonus pool for fewer high performers, and also likely more negative payment adjustments since the COVID exemption was no longer automatic in 2022. However, the bonus pool no longer exists after 2022. Additionally, the proposed 2024 Medicare proposed rule for the QPP makes it more difficult to reach these levels of performance: scoring complexity changes the amount measures are worth, the performance threshold increases, and data completeness requirements increase. The CAP expects that 2023 scores may not be as high as 2022, especially for high performers.

The CMS has released several resources for more information, including:

If a physician believes there was an error in the calculation of the MIPS final score, he or she should request an appeal, which the CMS calls a targeted review, by October 9, 2023. For more information about how to request a targeted review, please refer to the 2022 Targeted Review User Guide.

The CAP’s registry offers the highest scoring opportunities for pathologists. If you have any questions or want to talk to the CAP about MIPS, email mips@cap.org.

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