MIPS 2023 Reporting Period Overview

Payment Threshold Challenges

During the MIPS 2023 reporting period, the payment threshold remains set at 75 points, presenting challenges for providers aiming to achieve the required score amidst the program’s changes.

MIPS 2023 and Program Modifications

Final Rule Release

The Centers for Medicare and Medicaid Services (CMS) released the MIPS 2023 Final Rule, confirming that most of the proposed changes outlined in the previous July proposal will take effect.

Challenges Faced in MIPS 2023

Historically high-scoring Quality Measures have been removed from the program, leading to concerns about identifying Quality Measures that can yield the full 10 points. Additionally, CMS will not provide tools for monitoring the Cost performance category during the performance year.

Cost Performance Category Insights

Providers will be evaluated based on their performance relative to peers, with group scores projected to hover around 15 out of 30 points. This indicates that if any cost category measures apply to a provider’s reporting, they could miss out on 15 of their total 100 points in their MIPS score.

MIPS Value Pathways (MVP) Scoring Challenges

The MVP scoring process in MIPS 2023 presents additional difficulties. Each MVP includes at least one population health measure, yet teams lack clarity on how these measures will impact their scores, resulting in reduced visibility into final scores.

Reporting Mechanisms and Penalties

Due to the complexity of various reporting options, including “simple” mechanisms like eCQMs from certified electronic health record technology (CEHRT), providers risk incurring penalties. Achieving a score of 20 out of 30 in the Quality category or an average of 7 points for each reported measure requires flawless scores in Promoting Interoperability (PI) and Improvement Activities (IA).

Strategies for Effective Reporting

Given the variety of reporting options in MIPS 2023, it is advisable for providers to begin data collection early and assess mid-year results to identify the most effective reporting strategies. The focus should be on reaching optimal reporting conditions.

MVP/MIPS 2023 Focus Areas

MVP/MIPS 2023 emphasizes specialty areas and narrows quality reporting to just four measures.

Participation Options in MIPS 2023-2025

Types of Participants

Participants in the MIPS 2023-2025 performance period include:
– Sub-group
– Individual Clinician
– Alternative Payment Model Entity
– Single or Multi-specialty Group

The specialty type is determined through Medicare Part B claims, with multi-specialty groups defined as comprising two or more specialties.

Understanding Subgroup Reporting

A subgroup refers to a subset of a group that includes at least one MIPS-eligible clinician, identifiable by the group TIN, subgroup identity, and the NPI of each eligible clinician. CMS permits subgroup reporting only for physicians who report through MVPs or the APM Performance Pathway.

Future of Subgroup Reporting

Subgroup reporting will be optional for the performance years 2023, 2024, and 2025. Beginning in 2026, multi-specialty groups will be required to organize into subgroups for MVP reporting.

Eligibility and Registration Criteria

Clinicians planning to participate as a subgroup are determined by CMS using the first 12-month period of the 24-month MIPS determination period. Subgroups are subject to eligibility and special status criteria based on the connected group’s TIN. Due to implementation issues, CMS will not allow voluntary reports, opt-in eligible doctors, or virtual groups to submit MVPs for the MIPS 2023 performance year.