MIPS 2024 Final Rule Updates: Part IV

P3 Care, as a MIPS qualified registry, presents a series of blogs on the updates to the MIPS final rule for CY 2023. This article represents ‘Part IV’ of our coverage of the CY 2024 MIPS policy changes.

Overview of MIPS 2024 Guidelines

The MIPS 2024 final rule offers detailed guidelines encompassing all facets of reporting. Previous articles in this series discussed the changes in MIPS performance categories and final scoring. If you haven’t had the chance to read those insights, we encourage you to explore Parts I, II, and III of our blog series. Today, we will focus on the policy updates affecting third-party intermediaries.

Introduction to Third-Party Intermediaries in MIPS Reporting

Third-party intermediaries are specialized external entities that facilitate and streamline the MIPS reporting process. Throughout the performance year, they assist providers in meeting their reporting obligations.

Roles of Third-Party Intermediaries in MIPS 2024 Reporting

Third-party intermediaries can assume various roles in MIPS 2024 reporting, including:

  • Data aggregation and submission
  • Technology integration
  • Performance analysis
  • Regulatory compliance
  • Education and training

P3 Care also fulfills the role of a MIPS qualified registry, offering consulting services to aid providers in achieving positive performance outcomes.

MIPS 2024 Policy Updates for Third-Party Vendors

The new policy updates for MIPS 2024 impact third-party vendors in various ways, particularly affecting the following categories:

Health Information Technology (IT) Vendors

Health IT vendors serve as third-party entities that submit MIPS data to CMS on behalf of clinicians. They support data submission across all MIPS performance categories, including those participating through the Advancing Care Information (APP) initiative. Fiscal Year 2023 marked the inaugural year for MVP reporting, during which CMS permitted IT vendors to submit data for MVP participants. However, the MIPS 2024 final rule indicates that health IT vendors will no longer be recognized as third-party intermediaries starting in 2025. Consequently, FY 2024 will be the last year for these vendors to submit MIPS data on behalf of clinicians as CMS enhances data integrity protocols for third-party vendor requirements.

To continue reporting on behalf of clinicians, health IT vendors must register as Qualified Clinical Data Registries (QCDRs). The registration process for QCDRs will occur in CY 2024, allowing these vendors to assist with data collection and submission.

New Policies for QCDRs and Qualified Registries

The MIPS 2024 policies outline several key aspects for QCDRs and qualified registries:

Self-Nomination and Approval

CMS has established simplified self-nomination requirements for existing QCDRs and qualified registries in good standing. Under the new standards, these entities must provide MVP titles and ensure the inclusion of accurate measures and activity identifiers for the Improvement Activities (IA) and Promoting Interoperability (PI) categories. CMS has also strengthened its criteria for nomination rejections, adding “measures submitted after self-nomination” as a reason for QCDR measure rejection. Furthermore, QCDRs are required to publicly post their approved measure specifications during the performance and submission periods.

Additionally, QCDRs and qualified registries must attest to the following:

  • Granting CMS permission to review data upon request
  • Confirming the accuracy of their information in qualified postings

CMS has differentiated the sampling methods for data validation audits for third-party vendors in the MIPS 2024 rule.

Policies for Remedial Action and Termination

The MIPS 2024 policies regarding remedial actions and terminations specify that:

  • Publicly qualified postings will serve as the source of updates concerning remedial actions and terminations.
  • Failure to provide and maintain updated information may result in remedial action or termination.
  • Intermediaries must inform CMS upon completion of Corrective Action Plans (CAPs).
  • Remedial action for consecutive years may lead to termination of the intermediary.

Support for MVPs

Intermediaries are required to support all measures and IAs within the MVP, with two exceptions for specialty limitations. In a multi-specialty MVP, QCDRs and qualified registries are responsible for supporting only the relevant measures. Reporting QCDR measures is exclusive to the measure owner, and support from the QCDR is contingent upon obtaining appropriate permissions for measures not owned by them.

Conclusion

In summary, the policies for third-party intermediaries in MIPS 2024 require careful consideration. Providers must evaluate their specific needs, including expertise, technology, and resources, to ensure effective support for MVP reporting. P3 Care is a CMS-trusted qualified registry that offers MIPS consulting services to enhance your MIPS reporting experience. Contact us to optimize your success in MIPS 2024 and beyond, ensuring a collaborative approach that addresses your needs and informs your strategic decisions.