MIPS Program Update: Transitioning to MIPS 2024

Current Participation and Adjustments

The MIPS program is advancing towards MIPS 2024, while clinicians are currently engaged in MIPS 2023. Concurrently, adjustments from the MIPS 2022 reporting year are underway, including payment adjustments for Performance Year (PY) 2022, which will be implemented in Calendar Year (CY) 2024. Recently, the Centers for Medicare & Medicaid Services (CMS) announced the final preview score period, allowing MIPS participants to review their scores. While these scores are preliminary, adjustments may occur before final payment determinations.

MIPS Exception Applications for 2023 Participants

A significant development for MIPS 2023 participants is the opportunity to apply for MIPS Exception applications. The application window is open until 8 p.m. ET on January 2, 2024.

Overview of MIPS 2024 Rulemaking

In this blog, we will explore the strategies and motivations behind the recent changes to MIPS rules. CMS typically bases its decisions on thorough analysis rather than arbitrary choices. The agency welcomes public requests and feedback, proposing solutions to address issues and opening a comment period for further input before finalizing its decisions.

On July 13, CMS released the proposed rule for MIPS 2024, outlining forthcoming changes to the program. Although not a final rule, it provides clinicians with guidance to adjust their MIPS strategies in anticipation of the new year.

The End of Public Health Emergency and Its Impact

Challenges During the COVID-19 Pandemic

The COVID-19 pandemic significantly impacted the healthcare landscape, presenting daunting challenges for clinicians managing a surge of patients. Despite the obstacles posed by quarantine and lockdown measures, healthcare providers demonstrated exceptional resilience and dedication. CMS responded to this public health emergency (PHE) by implementing relaxations in MIPS requirements during the pandemic.

After nearly three years of navigating the pandemic’s challenges, CMS is now transitioning away from the PHE framework and returning to a focus on the Quality Payment Program (QPP). The proposed MIPS 2024 rule reflects this shift, with special attention given to several key areas.

Key Focus Areas in MIPS 2024 Proposed Rulemaking

The proposed rule emphasizes:
– Development and maintenance of MIPS MVPs (MIPS Value Pathways)
– Utilization of digital measurement and health IT
– Ensuring the integrity of program data (safe, secure, and accurate)
– Assessing potential returns on investment

Development and Maintenance of MVPs

Transition from MIPS to MVPs

Clinicians are familiar with the transition from MIPS to MVPs, a change announced by CMS in the final rule for PY 2023. To facilitate this transition, MVPs were introduced as a voluntary reporting option for the current year. For PY 2024, five new MVPs have been proposed:
1. Putting Women’s Health First
2. Providing High-Quality Care for Ear, Nose, and Throat Disorders
3. Management of Infectious Diseases (HIV and Hepatitis C)
4. Quality Care for Substance Use Disorders and Mental Health
5. Support for Musculoskeletal Rehabilitation

CMS will update MVPs based on inclusion criteria and feedback received during the maintenance process, aiming to capture quality metrics relevant to specialists within the Universal Foundation.

Consolidation of Existing MVPs

CMS plans to consolidate two previous MVPs—Promoting Wellness and Optimizing Chronic Disease Management—into a single primary care MVP, aligning quality measures with the adult core set of the Universal Foundation.

New Reporting Options for Medicare ACOs

Introduction of CQMs

The proposed rule for PY 2024 has introduced a new collection type for Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs). ACOs can now participate in MIPS using Clinical Quality Measures (CQMs) under the APM Performance Pathway (APP). This new collection type aims to prepare ACOs for the all-payer/all-patient MIPS CQMs and electronic CQMs.

Ensuring Data Integrity in MIPS

Addressing Data Submission Issues

CMS has observed inaccuracies in data submissions from Health IT vendors, primarily due to the lack of data validation requirements. To address this, CMS has proposed eliminating this specific type of third-party intermediary from MIPS for PY 2025. However, vendors can still participate if they nominate themselves as Qualified Clinical Data Registries (QCDRs) or MIPS-qualified registry members.

Enhancing Return on Investment

Proposed Performance Threshold Increase

CMS aims to achieve greater returns on its investment in MIPS participation. Traditionally, the agency provides positive payment adjustments for high scores. In line with this goal, CMS has proposed a modest increase in the performance threshold for the three MIPS reporting options, raising it from 75 to 83 points.

Conclusion

As the MIPS program progresses toward MIPS 2024, it is essential for clinicians to stay informed about the new rule changes to adapt their strategies effectively. For the latest updates regarding MIPS, follow P3 Care. As a MIPS-qualified registry, we monitor every development closely. Embrace the transition to MVPs for a more focused and impactful MIPS experience through our consulting services.