Introduction to MIPS Reporting Season

Celebrating MIPS Participants

Congratulations to all MIPS participants who have maintained their eligibility for MIPS 2023. As the 2023 performance period draws to a close, clinicians will soon transition into the reporting phase.

Announcement of MIPS 2024 Final Rule

In a forward-looking move, the Centers for Medicare & Medicaid Services (CMS) has released the Physician Fee Schedule (PFS) final rule for MIPS 2024. It is crucial for eligible MIPS participants to prepare for Performance Year (PY) 2024 by revisiting their strategies. Before that, it is important to review the regulatory updates for Calendar Year (CY) 2024.

Maintaining Flexibility in Reporting

The 2024 reporting rule emphasizes flexibility, aligning with the original goals of MIPS. The PFS final rule for MIPS 2024 includes detailed information regarding policy changes.

Overview of MIPS Policy Changes

This blog marks ‘Part I’ of our series on MIPS final rule updates for CY 2023. Here, we will focus on the quality and cost performance categories of the MIPS program. MIPS participants have three reporting options:

  • Traditional MIPS
  • MIPS Value Pathways (MVPs)
  • Alternative Payment Model (APM) Performance Pathway (APP)

CMS has made revisions to the MIPS policy for each of these reporting options, which we will explain in detail.

Quality Performance Category

Retention of Scoring Proportion

The quality category continues to represent 30% of the final MIPS score.

Quality Measure Inventory

A total of 198 quality measures are available, excluding QCDR measures. CMS has added 11 new quality measures while removing an equal number. Additionally, three measures are partially removed, and 59 existing measures have undergone significant changes.

Collection Types for Quality Reporting

ACOs have faced challenges with data aggregation and patient matching when reporting electronic Clinical Quality Measures (eCQMs) and MIPS Clinical Quality Measures (CQMs) under the APP. The new rule introduces a collection type specifically for ACOs, termed ‘Medicare ACO.’ Participants in the Medicare Shared Savings Program (MSSP) are required to report data on Medicare beneficiaries.

Data Completeness Criteria

The data completeness criteria for quality measure reporting remain unchanged from MIPS 2023, setting a 75% threshold for all collection types. This includes Medicare CQMs, with the threshold clearly established for the 2024, 2025, and 2026 performance periods.

CAHPS for MIPS Survey

Spanish translation of the survey is available for Spanish-preference patients. MIPS participants can coordinate with their survey vendors to ensure administration in Spanish and other required languages.

ICD-10 Coding Changes

Updates to ICD-10 codes will continue over time. The MIPS 2023 quality measure included criteria for addressing ICD-10 coding changes, which previously allowed measure suppression based on a 10% threshold. The PFS final rule for MIPS 2024 eliminates this automatic threshold, introducing new criteria that require case-by-case assessment of coding changes.

Cost Performance Category

Cost Category Score Assignment

CMS will automatically assign scores for applicable cost measures within the cost category. The PFS final rule for MIPS 2024 introduces updates to score calculation and scoring policies.

Cost Improvement Scoring Methodology

Current MIPS policy necessitates cost improvement score calculations at the measure level. CMS has revised the calculation methodology for cost performance at the category level, effective from the CY 2023 performance period into the 2025 MIPS payment year, while excluding statistical significance. This approach assures mathematical and operational viability for cost-performance scoring enhancements.

Conclusion

In summary, the MIPS 2024 policy updates significantly impact the quality and cost performance categories, which are critical in determining the final MIPS score. Understanding the policy changes in these categories is essential for providers. For further assistance, consider our MIPS consulting services, where our expert team is ready to support your success in MIPS reporting.