CMS Releases MIPS 2024 Final Rule
Overview of the Final Rule
Providers, it’s time to prepare! The Centers for Medicare & Medicaid Services (CMS) has announced the final rule for the Merit-based Incentive Payment System (MIPS) in 2024. Prior to finalizing the reporting policies for Performance Year (PY) 2024, CMS had already shared a proposed rule. Clinicians should remain vigilant as CMS is actively setting performance criteria and scoring standards for Calendar Year (CY) 2024. It is essential for clinicians to engage fully in the ongoing healthcare improvement initiatives.
Understanding the Proposed Changes
Before delving deeper into the details, it is important for clinicians to familiarize themselves with the changes introduced in the proposed rule for MIPS 2024. This provides a foundational understanding of the upcoming rules and their implications. Clinicians should enter PY 2024 with a clear focus on their goals.
MIPS 2024: Returning to Core Principles
Background of MIPS Program
The MIPS program has been operating successfully under the Quality Payment Program administered by CMS. Over the years, the federal government has implemented constructive changes to the program. These modifications were driven by various factors, including the push for value-based care across the healthcare landscape. Despite this momentum, challenges remained, which CMS aimed to address progressively.
Impact of COVID-19 on MIPS
The COVID-19 pandemic significantly disrupted the healthcare system, as providers worked tirelessly to ensure patient care. In response, CMS offered several relaxations to alleviate the stress on healthcare providers during the public health emergency.
Transitioning Back to Original MIPS Reporting
With the healthcare industry now recovering from the pandemic, CMS has decided to revert to the original MIPS reporting framework for CY 2024. The final rule includes policies that emphasize continuity, digital measurement, and interoperability. Additionally, CMS is intensifying its focus on developing MIPS Value Pathways (MVPs).
Key Policies Approved for MIPS 2024
Introduction of New MVPs
The MIPS final rule for 2024 introduces five new MVPs aimed at achieving future objectives. Additionally, some existing MVPs have undergone modifications. Clinicians now have 16 finalized MVPs available for PY 2024 reporting.
List of New and Modified MVPs
New MVPs:
– Rehabilitative Support for Musculoskeletal Care
– Quality Care for the Treatment of Ear, Nose, and Throat Disorders
– Quality Care in Mental Health and Substance Use Disorders
– Prevention and Treatment of Infectious Disorders, Including Hepatitis C and HIV
– Focusing on Women’s Health
Modified MVPs:
– Improving Lower Extremity Joint Repair Care
– Suitability for Individuals with Intermittent Neurological Disorders
– Neurodegenerative Disease Supportive Care
– Adopting Best Practices in Emergency Medicine and Promoting Patient Safety
– Improving Oncology Care
– Cardiovascular Disease Care Advancement
– Rheumatology Patient Care Advancement
– Stroke Care Coordination to Promote Prevention and Positive Outcomes
– Kidney Health Care at Its Finest
– Patient Safety and Encouragement of Positive Anesthesia Experiences
– Primary Care Value
Performance Period for the PI Performance Category
Clinicians will have a 180-day performance period for the Promoting Interoperability (PI) performance category, aligning with CMS’s growth strategy and the Medicare PI Program.
Medicare CQMs for ACOs
CMS has approved the collection of Medicare Clinical Quality Measures (CQMs) for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP) under the Medicare CQMs collection type, applicable to ACOs that meet reporting requirements within the APM Performance Pathway (APP).
Pending Policies for MIPS 2024
Performance Threshold Expectations
During the rulemaking period, many anticipated changes to the performance threshold. Historically, CMS has adjusted this threshold; however, the final rule for PY 2024 maintains the performance threshold at 75 points. Clinicians scoring below this threshold will face penalties.
Data Completeness Requirements
There have been no updates to the data completeness requirements. Additionally, any decision regarding an increase in the data completeness threshold for 2027 remains pending.
Qualifying APM Participant (QP) Determinations
CMS has confirmed that QP determinations will continue to be made at the APM entity level, as in the past. There are currently no policies finalized for individual clinician level QP determinations.
Conclusion
This overview of the MIPS 2024 final rule aims to assist clinicians in preparing for the upcoming reporting year. It is advisable to reassess reporting strategies and seek assistance from MIPS-qualified registries for effective planning. Utilizing MIPS consulting services can help identify deficiencies and enhance performance in MIPS.