MIPS 2022: Do you Need to Report?

As MIPS reporting is coming to an end for 2021, practices nationwide are asking themselves if they need to start preparing for 2022.  There are additional updates to the reporting requirements this year – more on that in a follow up post – but the first step is to check if you are eligible to report MIPS as an individual or as a group.

Background

Confirming your reporting requirements is easy with CMS’s Check Your Participation Status tool. Simply input your NPI number and it will display the current eligibility and various considerations. Some of the top items to look out for are: 

1. Individual eligibility
2. Group eligibility
3. Special status – hospital based
4. Special status – small practice

Checking now is a great way to give you an indication as to what your best strategy is for 2022, but do keep in mind that CMS will be updating the records around November, so make sure to check again after final eligibility is released.

What about the COVID-19 exemption?

With the COVID-19 pandemic and public health emergency, CMS granted exemptions from the MIPS reporting program through the MIPS Extreme and Uncontrollable Circumstances policy.  In prior years, this exemption applied to practices that have been in a natural disaster or are located in a FEMA designated disaster area.

The COVID-19 public health emergency became an automatic exemption for all groups, allowing flexibility for providers to not report and not incur penalty adjustments on claim payments. This exemption was available for report years 2019-2021, but what about 2022?  

There is good news for physicians needing relief as the pandemic continues!  CMS has published on the QPP website that the Extreme and Uncontrollable Circumstances policy will be used and available to clinicians who are unable to report in 2022.  There has not been any news regarding whether this will be automatic like in prior years.  Accordingly, clinicians and their practices should monitor the QPP website as the year progresses for additional details on if an application will be required by the end of the year.