The Importance of MIPS for Healthcare Providers

Reshaping the Healthcare Landscape

The Merit-based Incentive Payment System (MIPS) presents a significant opportunity for healthcare providers to enhance their performance. The Centers for Medicare & Medicaid Services (CMS) is actively working to transform the healthcare framework through the MIPS reporting structure. As the healthcare environment evolves, CMS remains focused on improving the quality of care delivery by establishing milestones for practitioners to meet. Once these milestones are reached, CMS promptly sets new targets, maintaining its commitment to quality improvement.

Proposed Rule for MIPS 2024

Each year, CMS releases the proposed rule for MIPS reporting, and recently, the proposed rule for MIPS 2024 has been unveiled. A notable aspect of this process is the opportunity for stakeholders to provide input. Following the release of the proposed rule, a commenting period begins, allowing relevant personnel and providers to submit feedback. CMS carefully considers these suggestions before finalizing the rule. Currently, we are in the commenting period for the MIPS 2024 proposed rule.

Key Changes in MIPS 2024

Performance Threshold Adjustments

On July 13, 2023, CMS published detailed information regarding the proposed MIPS 2024 rule on the Quality Payment Program (QPP) website. The commenting period is open until September 11, 2023. One of the most significant changes is the increase in the performance threshold to 82 points, based on mean final scores from 2017 to 2019.

Participants in MIPS 2024 must achieve at least 85 points to avoid penalties. Scores falling below this threshold may incur a penalty of up to -9%, while scores exceeding 85 points could earn incentives of up to +9%.

Updates to MIPS Categories

Quality Category Changes

Data completeness remains essential for competitive performance in MIPS. For MIPS 2024, the data completeness threshold is set at 75% for all quality measures reported, reflecting a 5% increase from the previous year. Medicare Clinical Quality Measures (CQMs) must also meet this criterion. Proposed thresholds for future performance years include:

– 2025: 75%
– 2026: 75%
– 2027: 80%

The measure inventory for MIPS includes a total of 200 quality measures, with 14 new measures proposed, 12 measures removed, three measures retained for Merit-based Incentive Payment System (MVP) reporting, and 59 measures revised.

New Collection Type for Medicare ACOs

To address past challenges in reporting electronic CQMs and MIPS CQMs, CMS has introduced a new collection type for Medicare Accountable Care Organizations (ACOs) under the Alternative Payment Models (APM) category.

Cost Category Modifications

CMS proposes to calculate improvement scoring for the cost performance category at the category level without relying on statistical significance, starting with the CY 2023 performance period for the 2025 MIPS payment year. The maximum cost improvement score is suggested to be one percentage point out of a possible 100.

New episode-based cost measures for the 2024 performance period include Depression, Emergency Medicine, Heart Failure, Low Back Pain, and Psychoses and Related Conditions, while the measure for simple Pneumonia with Hospitalization will be excluded.

Improvement Activities (IA) Category Changes

The proposed rule for MIPS 2024 includes five new Improvement Activities, although three existing activities are set to be removed.

Promoting Interoperability (PI) Category Updates

The proposed MIPS 2024 rule suggests extending the performance period for Promoting Interoperability from a minimum of 90 continuous days to at least 180 continuous days. Additionally, the definition of Certified Electronic Health Record Technology (CEHRT) is proposed to be updated to align with the ONC health IT certification criteria.

For APMs, the requirement that 75% of clinicians use CEHRT is proposed to be removed, allowing flexibility in meeting the Base EHR definition.

Automatic Reweighting and Measure Changes

CMS is reconsidering automatic reweighting for certain clinician types as outlined in the proposed rule. The continuation or discontinuation of reweighting will affect various clinician groups, including physical therapists and clinical social workers.

Moreover, two significant measure changes are proposed: modifying the exclusion for the Prescription Drug Monitoring Program (PDMP) Measure to support clinicians not electronically prescribing certain controlled substances, and mandating a “yes” response for the SAFER Guide measure starting in performance year 2024.

Conclusion

The proposed changes under MIPS 2024 signal substantial updates to the Quality Payment Program. These modifications will influence reporting practices across traditional MIPS, APMs, and ACOs, necessitating that clinicians review these updates to understand their potential impact on reporting for the upcoming year. The Final Rule is expected to be published later this fall.

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