MIPS Final Rule Updates for CY 2024: Part II
Introduction
P3 Care, a MIPS-qualified registry, continues its series of blogs on updates to the MIPS final rule for CY 2023. This article is the second part of our exploration into the MIPS policy changes for CY 2024. The PFS final rule serves as a vital resource for providers to navigate the complexities of MIPS reporting.
Overview of Previous Blog
In Part I of our blog series, we outlined the rules and parameters related to the quality and cost categories, discussing essential elements such as quality measures, data completeness thresholds, and cost scoring.
Focus of Current Blog
This installment will delve into the remaining two MIPS performance categories: Promoting Interoperability (PI) and Improvement Activities. These categories highlight a commitment to enhancing patient experiences through technological advancements and overall healthcare improvements.
Improvement Activities Performance Category
IA Measure Inventory
The PFS final rule presents the updated IA measure inventory, which includes 106 improvement activities that are yet to be finalized. Notably, five new activities have been added, including an MVP-specific activity titled “Practice-Wide Quality Improvement in MVPs.” Additionally, three improvement activities have been permanently removed, while one has been modified.
Promoting Interoperability Performance Category
Criteria for Certified EHR Technology (CEHRT)
The new rule revises the criteria for utilizing CEHRT within the healthcare system. The requirement to adhere to the 21st Century Cures Update of health IT certification criteria has been eliminated. For MIPS 2024, health IT must now comply with ONC regulations, moving away from the previous ‘2015 edition’ criterion. CMS will adopt new criteria as outlined in CFR 170.315. MIPS participants are required to implement CEHRT that meets the current and future definitions established by ONC.
CEHRT Threshold Policy for Shared Savings Program ACOs
There will be no changes to the CEHRT threshold policy for Medicare ACOs for MIPS 2024. Although CMS has proposed potential modifications for future performance years, the current policy remains unchanged. Under this policy, ACOs in specific tracks must ensure that participating clinicians utilize CEHRT for documenting and sharing patient information. The required proportion of clinicians using CEHRT varies by track; for example, tracks A–D require 50% compliance, while tracks E and ENHANCED require 75%.
Automatic Reweighting Policy
CMS has amended its automatic reweighting policy. Certain clinicians may benefit from the reweighting of the PI category to 0% of the final score, with the weight redistributed among the other MIPS categories. For MIPS 2024 reporting, the rule indicates the discontinuation of automatic reweighting for specific clinician types, including physical therapists, occupational therapists, qualified speech-language pathologists, clinical psychologists, and registered dietitians/nutrition professionals. However, clinical social workers will continue to benefit from PI category reweighting, alongside clinicians and groups with special statuses such as ambulatory surgical center-based, hospital-based, non-patient facing, and small practices.
Performance Period
Beginning in FY 2024, the federal government has extended the performance period to 180 continuous days within the calendar year. This change is strategic, allowing the MIPS PI category to align with the Medicare PI program for eligible hospitals and critical access hospitals.
Measure Points
Clinicians are now required to certify their use of the High Priority Practices SAFER Guide by responding “yes” as part of the Measure Points requirement starting with the CY 2024 performance period.
Conclusion
This concludes our examination of the MIPS 2024 final policies for the Promoting Interoperability and Improvement Activities categories. For further details and guidance, we invite you to reach out for our MIPS consulting services. Please leave your questions and concerns in the comment section below, and our experts will provide assistance to enhance your understanding.