A new year means new updates to MIPS. The 2023 Merit-Based Payment System Final Rule was recently published by The Centers for Medicare and Medicaid (CMS) with Health and Human Services. These notices are packed with much detail and run for many pages, but this article shares the highlights of what is to come.
What is MIPS?
The Merit-Based Payment System (MIPS) is part of the CMS’ Quality Payment Program. It is intent on incentivizing doctors and other healthcare providers to deliver better-quality and more cost-effective care to Medicare beneficiaries. Providers whose patient population includes a significant number of Medicare beneficiaries may financially benefit from this program.
Participating providers are evaluated according to a set of four performance categories: quality, cost, advancing care information, and improvement activities. Depending on the quality score outcome, providers will have a positive, negative, or neutral payment adjustment applied to their Medicare Part B payments.
Do you need to file a Hardship for MIPS this Year?
The answer is yes – and do not delay! Apply for an Extreme and Uncontrollable Circumstances hardship exception to avoid a 9% MIPS penalty due to the impact of the COVID-19 public health emergency (PHE). The penalty would apply in 2025 based on the 2023 performance period.
For PY2023, the exception is not automatic; therefore, interested physicians and groups must actively request reweighting of one or more of the MIPS performance categories due to COVID-19. Requesting reweighting of all four MIPS performance categories would avoid a MIPS penalty in 2025.
There are two exception applications available to clinicians in PY2023:
- The MIPS Extreme and Uncontrollable Circumstances (EUC) exception application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance or public health emergency (PHE), such as COVID-19, which is outside of our control.
- The MIPS Promoting Interoperability Performance category hardship exception application allows you to request reweighting specifically for the Promoting Interoperability performance category if you qualify.
You can submit a MIPS Extreme and Uncontrollable Circumstances (EUC) Exception or a MIPS Promoting Interoperability Performance Category Hardship Exception application for PY 2023 anytime through 8 p.m. EST on January 2, 2024.
Changes to the MIPS Program for Performance Year 2024
After five years, the special COVID hardship waiver has ended. In 2024, MIPS will be fully in force for all eligible clinicians, across all specialties. A total of 198 quality measures were finalized for the 2024 performance period resulting in:
- Removal of 11 quality measures
- Modification of 59 existing measures
- Addition of 11 new quality measures
With the push to transition to MIPS Value Pathways (MVPs), CMS has finalized five new MVPs and modified the previously 11 finalized MVPs. There will be 16 MVPs available for reporting in the 2024 performance period. The identification of MIPS MVPs typically occurs after the performance year’s end and is based on various performance metrics and criteria set by CMS.
The performance threshold for the 2024 MIPS performance year will remain at 75 points. CMS proposed an increase in the performance threshold to 82 points for the 2024 performance year, but this proposal was not finalized.
Data Completeness Threshold
CMS previously finalized an increase to the data threshold requirement. Now 75% data completeness is required for the 2024 and 2025 performance periods (up from 70% in 2023) for all:
- MIPS CQMs
- QCDR measures
- Medicare Part B claims measures
This means that Quality measures must be reported on a minimum of 75% of eligible cases for the year.
Significant Changes by Category
With each annual final rule publication comes much detail about MIPS changes, especially pertaining to each category. Here are the most noteworthy updates for 2024:
- Quality performance category – There are no significant changes for scoring or reporting in this category.
- Cost performance category – The proposed changes for the 2024 MIPS performance year include allocating 30% of the total score to the cost performance category.
- Improvement activities (IA) performance category – The proposed changes for the 2024 MIPS performance year include allocating 15% of the total score to the IA performance category.
- Promoting interoperability (PI) performance category – The performance period for the PI category will increase from a minimum of 90 continuous days to a minimum of 180 continuous days.
Additional Changes to Improvement Activities
For the 2024 MIPS performance year, additional proposed changes to the IA category include:
- Expanded reporting criteria – CMS has proposed several changes to the IA reporting criteria. These changes aim to streamline and simplify reporting requirements, making it easier for eligible clinicians to participate in MIPS.
- New improvement activities – CMS has also proposed adding new improvement activities to the list of options available. These activities focus on areas such as telehealth, care coordination, and patient engagement.
It is important to review official sources for the most up-to-date information and further details on the specific improvement activities and their requirements. Or reach out to an experienced MIPS healthcare consultant.
Category weights for 2024 are set at:
- 30% for quality
- 30% for cost
- 25% for promoting interoperability
- 15% for improvement opportunities
Small Practices (Those with 15 or fewer clinicians)
- 50% for quality
- 20% for improvement opportunities
- 30% for cost
5 Step MIPS Checklist to Improve Performance for Performance Year 2024
While understanding all these rule changes can be complex, there are best practices medical organizations of all kinds can follow to help improve their MIPS performance. We have compiled a checklist of five actions you can take to prepare for 2024.
5 Step MIPS Checklist Overview
- Determine Which MIPS Data You Need to Submit
- Determine Which MIPS Framework You Should Use to Submit Your Data
- Research and Understand Changes to MIPS Scoring for 2024
- Evaluate Your Projected MIPS Performance and Adjust Accordingly
- Hire a MIPS Expert
For play-by-play guidance on how to complete these steps, check out our complete and detailed MIPS Checklist for 2024.