P3 Care’s MIPS Final Rule Updates for CY 2024

P3 Care, a qualified MIPS registry, is pleased to present a series of blogs focusing on updates to the MIPS final rule for CY 2023. This article marks ‘Part III’ of our discussion on the MIPS policy changes for CY 2024.

Overview of MIPS Reporting Rules

The MIPS reporting rules and policies differ across various reporting options. The PFS final rule for MIPS 2024 briefly outlines the updates applicable to all three reporting options. For those who are new, we encourage you to review our earlier blogs, Part I and Part II, which detail the revisions to the MIPS 2024 reporting policy. In the previous installments, we covered modifications to the four MIPS performance categories. In this ‘Part III,’ we will delve into any final scoring policy updates in detail.

Understanding MIPS Final Scores

MIPS final scores are derived from the CMS evaluation of clinician performance across four categories. Participants receive scores based on reported measures and activities within these categories. By aggregating the percentages from each category, CMS calculates the MIPS final scores. A total score ranging from 0 to 100 points influences the Medicare Part B payment adjustments, determining whether the adjustments will be positive, negative, or neutral in the coming years.

It is important to note that the scoring for small practices or participants with special status may differ. Clinicians can also apply for exceptions during the performance period. If CMS finds an applicant eligible for an exception, the percentage for that category is redistributed, effectively counting as zero.

MIPS 2024 Policy Updates for Final Scoring

The Physician Fee Schedule Final Rule for MIPS 2024 introduces several key policy updates regarding final scoring.

Facility-Based Scoring

This update primarily affects participants reporting through MIPS Value Pathways (MVPs). Previously, clinicians participating as subgroups in MVPs received facility-based scores where applicable. The new MIPS 2024 policy eliminates facility-based score calculations at the subgroup level for two main reasons:

  • The PFS final rule does not include any facility-based MVPs.
  • Facility-based scoring is only available for traditional MIPS participants, and subgroup participation is not an option within this reporting framework.

Clinicians or groups working within a facility may choose to report an MVP or Alternative Payment Model (APM). In such cases, CMS will calculate a final score using both facility-based measurements and the score from MVP or APM reporting, awarding the higher of the two scores.

Complex Patient Bonus

Subgroups reporting via MVPs can now qualify for the complex patient bonus, if available. CMS has added § 414.1365(e)(4)(i) to the Code of Federal Regulations, confirming that clinicians participating as a subgroup in PY 2023 will receive this bonus if they meet the eligibility criteria.

Performance Threshold

CMS proposed an increase in the performance threshold to 82 points, leading many clinicians to anticipate its implementation in the final rule. However, the MIPS 2024 final policy establishes the performance threshold at 75 points, thereby reducing the MIPS reporting burden on clinicians.

Targeted Review Timeline

The timeline for targeted review will commence once CMS releases the MIPS final scores for 2024. There are no changes to this timeline, which will remain open for 30 days following the payment adjustments. Clinicians will have a 60-day window to request a targeted review, starting 30 days before the release of payment adjustments and continuing for 30 days afterward. If CMS requests documentation during this period, responses must be provided within 15 days.

Conclusion

The MIPS 2024 policy introduces significant updates regarding final scoring. P3 Care, as a qualified MIPS registry, is here to help you navigate these changes. We have comprehensively covered the final scoring policy updates within MIPS reporting. Clinicians participating as subgroups should pay special attention to these modifications. Consider our MIPS consulting services to facilitate your transition into MIPS 2024.