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) in conjunction 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.
Changes to the MIPS Program for Performance Year 2023
For continued success in MIPS, providers must modify their performance strategy to align with updates published by CMS. While this summary is by no means comprehensive, you can use it to make key adjustments to your plans.
Overview – Most Notable Changes
198 quality measures have been finalized for the 2023 performance year. Of those:
- 76 were substantive changes
- Nine new measures added (such as the administrative claims measure)
- 11 quality measures have been cut (including those from multiple specialty sets)
Below, we have extracted from the changes the final rule we expect to have the most impact.
The Exceptional Performance Threshold – that granted additional positive payments to providers scoring 89 or above – was set to expire in 2022, so it will not carry over into 2023. As for the minimum performance threshold, clinicians and groups must gain at least 75 points to avoid a negative payment adjustment in 2025.
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.
In the area of Quality, the 3-point floor has been removed. In lieu of the 3–10-point scale, measures that have a benchmark, meet case minimums, and include data completeness will be scored 1–10-points.
No significant changes have been announced, but one item of interest is progress with the improvement score bonus. This addition is now final and will be 1% or less of the Cost category score based on measure-specific score improvements.
Expect three major changes with Performing Interoperability (PI).
- Query of Prescription Drug Monitoring Program (PDMP) is now a requirement whereas before it was considered optional for a bonus. The policy has been expanded to include Schedule III and Schedule IV prescriptions in addition to Schedule II opioids. Querying a PDMP would impose an excessive workflow or cost burden prior to the start of your selected 90-day performance period for a one-time exclusion in 2023.
- A new option, Participation in the Trusted Exchange Framework and Common Agreement (TEFCA) has been added to satisfy the Health Information Exchange Objective.
- It is now required to submit your level of engagement concerning registries claimed for PI – either “Pre-production and Validation” or “Validated Data Production.” However, Pre-production and Validation is limited to one year, after which you must move to Validated Data Production to gain credit for compliance.
Download Our 2023 MIPS Quality Measures Guide now!
Changes to existing IAs include use of QCDR data for practice improvement and assessment. Use of QCDR for feedback reports tied to population health has been removed. New IAs introduced are: Create and Implement a Language Access Plan (weighted highly) and COVID-19 Vaccination for Practice Staff (medium weighting).
Category weights will not change for 2023. Current weighting is set at:
30% for quality
30% for cost
25% for promoting interoperability
15% for improvement opportunities
Small Practices (Those with 15 or Fewer Clinicians)
40% for quality
30% for improvement opportunities
30% for cost
“MVP” Reporting Model
In 2023, the MIPS Valuable Pathways (MVP) is implemented. CMS summarizes MVP as, “a new, voluntary way to meet MIPS reporting requirements. Each MVP includes a subset of measures and activities that are related to a specialty or medical condition to offer more meaningful participation in MIPS.”
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 2023.
5 Step MIPS Checklist to Improve Performance for Performance Year 2023
5 Step MIPS Checklist Overview
For play-by-play guidance on how to complete these steps, check out our complete and detailed MIPS Checklist for 2023.