CEDR Program Update

Hello again CEDR participants, and we hope and pray for health and safety during this difficult time. We’ve seen visit volumes and utilization return to pre-COVID levels, but stress, staffing, and misinformation continue to plague our hard-working emergency medicine clinicians.

2022 is just around the corner, and it currently promises huge changes to the MIPS program from what we’ve been used to for the past three years. Because of the COVID-19 pandemic, CMS delayed the penalty phase-in and substantive bonus payments, resulting in neutral payment adjustments for the 2020 and 2021 performance years. But, in 2022, the MIPS program likely will resume with full implementation, with up to 9% penalties and bonuses for up to half of eligible clinicians.

By design, the 2022 performance year will determine clinicians’ 2024 Medicare Part B payments. In 2024 (payment year), the MIPS program is scheduled to penalize half of the eligible clinicians and reward the other half with bonuses, based on a MIPS score (0 to 100) calculated from the annual submission of 2022 performance data. Implementing a qualified MIPS reporting process can take several weeks, so now is the time to prepare.

The maximum penalty for the 2022 performance year is 9%, which is scaled based on the clinician’s MIPS score. Based on the 2020 Final Rule, clinicians will need to score at least 75 (median score) in 2022 to avoid a penalty, with scores above this mark resulting in bonuses. Simply put, CMS expects about half of all clinicians to fall below 75 and receive a penalty.

Will My Group Receive a Penalty or a Bonus?

The good news is that as part of the CEDR program, ACEP implements many custom measures specific to Emergency Medicine to assist in improving your scores in the program. While many of you have already implemented an electronic health record integration for your dashboard to enable these measures, I know that some of you still lack this capability. My team will be reaching out to all of you in the coming months to work diligently to activate this critical data feed which can enhance your competitive position in the MIPS program and maximize your potential score and bonus for 2022. Please also feel free to reach out to your CEDR Client Account Manager if you have any questions or concerns about these efforts.

Now, a word about 2021. As you may or may not know, CMS did retain the Extreme and Uncontrollable Circumstances exemption due to the impacts of COVID (or other natural disasters). I encourage you to take this exemption if you were impacted by COVID in 2021, even if you still plan to report. We don’t know what the future will bring in the last months of this year, and I would not want any group to get caught in a reporting issue due to a surge or other issue which would qualify for the exemption. CMS will accept your submission if you make one, regardless of if you applied for an exemption. One note, when requesting the exemption, do not request exemption from the Cost category. This is the one category that cannot be “undone” if the exemption is requested.  Request exemption from the Quality, Promoting Interoperability, and Improvement Activities only. You will get an email verification of your exemption shortly after the request. Make the request for each Tax ID Number (TIN) that your group uses with CMS. If you have a new TIN for this year, you may want to do individual exemptions for each of your physicians to ensure they are protected.

Another keynote for 2021 is that CMS removed the Hospital Value-Based Purchasing program scoring mechanism for MIPS. If in the past, you have used this for some of your TINs, you will need another pathway for reporting. Feel free to contact your CEDR Account Manager for assistance.

Bottom Line

We recommend group leaders carefully consider their approach to 2022 MIPS reporting NOW, well ahead of January 1, 2022. CMS is not expected to release rule updates for the 2022 reporting year until November 2021, so emergency physician groups should explore options and be prepared to act quickly. Given the recent challenges for our specialty, it will be especially important to preserve future Medicare reimbursement and avoid MIPS penalties moving forward.