Measuring quality and increasing MIPS reimbursement in 2022

Psychologists who serve Medicare beneficiaries are eligible (and sometimes required) to participate in the Merit-based Incentive Payment System (MIPS), one of two payment models within Medicare’s Quality Payment Program established to reward health care practitioners for the value and quality of services provided instead of the volume of patients seen.

If you’re required to participate in MIPS, now is the time to start preparing for MIPS reporting for 2022. Numerous changes make it more difficult to avoid penalties (negative payment adjustments) but increase the potential incentives.

Psychologists are not required to participate in MIPS if they fall under the low-volume threshold (LVT): 

• You bill less than $90,000 for Medicare services.
• You provide care for fewer than 200 Medicare Part B patients.
• You have less than 200 covered professional services.

However, psychologists who want to participate in MIPS to potentially receive reimbursement incentives may opt-in if they meet one of the LVT criteria, such as if they provide more than 200 Medicare-covered professional services. Clinical social workers are also eligible MIPS reporters for 2022.

For 2022 the minimum performance threshold, which is the number of points a provider must earn to avoid a penalty, has increased to 75 points from 60 points in 2021. Because of this, it is likely that more providers will be penalized; however, incentives will also be at the highest levels for top performers, with the payment adjustment remaining +/- 9%. 

So, what steps can you take to maximize your return on investment? 

• Get the most out of your quality measures by choosing the right ones. Consider measures available in qualified clinical data registries (QCDRs) and new measures that will yield at least 5 to 7 points.
• Have an internal meeting with your staff to discuss the importance of MIPS in 2022.
• Get the right tools in place: assessment tools or measure documentation checklists, electronic health record, billing process, and a platform for submitting measures to the Centers for Medicare and Medicaid Services (such as a registry).
• Start tracking now using a program like the Mental and Behavioral Health Registry (MBHR), a QCDR that can provide quality measure benchmarks early in the year.
• Track more than six quality measures (8–10) and watch their performance. You can eliminate measures throughout the year to optimize your time.

MIPS reporting can be challenging, especially finding quality measures that are meaningful to mental and behavioral health practitioners and your patients. APA has partnered with Healthmonix via the MBHR, gathering leading experts in the field to develop measures that are evidence-based, address gaps in care, and track patient outcomes. The MBHRopens in new window includes approximately 21 MIPS identified measures and 15 specialty measures, exclusive to the MBHR, for psychologists and other behavioral health practitioners to track and improve patient care, meet quality reporting requirements including those in MIPS, and keep your practice competitive.

The MBHR includes measures to screen for anxiety disorders and report anxiety disorder treatment response. It also includes measures related to impaired functioning, such as sleep quality, pain interference, and social role functioning. New for 2022 is a suite of quality process measures specifically for neuropsychology. 

Here are steps to take now to get 2022 quality reporting off to a strong start:

• Select measures that fit into your specialty and workflow by exploring the MBHR measures that match up with your patients and provided services.
• Determine measures that have smaller denominators.
• Identify measures that are not topped out (measures where performance is so high and unvarying that meaningful distinctions and improvement in performance can no longer be made).
• Find new measures that you can report that will yield at least 5 to 7 points:

• MBHR13 Social Role Functioningopens in new window (7)
• MBHR14 Sleep Quality Responseopens in new window (7)
• MBHR15 Cultural-Linguistic and Demographic Factors in Cognitive Assessmentopens in new window (7)
• MBHR 16 Comprehensive Cognitive Assessment Assists with Differential Diagnosisopens in new window (7)
• MBHR17 Improved Efficiency: Time Interval for reporting results of cognitive assessmentopens in new window (7)
• MBHR12 Provision of Feedback Following a Cognitive or Mental Status Assessment with Documentation of Understanding of Test Results and Subsequent Healthcare Planopens in new window (5)
• MBHR11 Cognitive Assessment with Counseling on Safety and Riskopens in new window (5)

In addition to access to relevant quality measures, the MBHR team at Healthmonix can guide you through the MIPS reporting process including offering tips on workflow, while the comprehensive, user-friendly platform gives you real-time feedback on your MIPS performance to ensure your success and maximize your reimbursement.