2024 QPP Final Rule

CMS recently published the CY 2024 Quality Payment Program (QPP) Final Rule which included numerous updates to MIPS Value Pathways (MVPs) and Merit-based Incentive Payment System (MIPS). For the full text of the rule, see the Federal Register.

MIPS Value Pathways (MVPs)

CMS continues to envision MVPs as the future of MIPS. Beginning with the 2024 performance year, CMS finalized 5 new MVPs, along with revisions to all previously finalized MVPs. Modifications to MVPs can be found in Group B of Appendix 3 in the Final Rule. There will be 16 MVPs available for reporting in the 2024 performance period.

The 5 new MVPs are:

• Focusing on Women’s Health
• Quality Care for the Treatment of Ear, Nose, and Throat Disorders
• Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
• Quality Care in Mental Health and Substance Use Disorders
• Rehabilitative Support for Musculoskeletal Care

CMS clarified that beginning with the 2023 performance period, subgroups reporting an MVP will receive their affiliated group’s complex patient bonus, if available. Further, CMS finalized that subgroups will only receive reweighting based on any reweighting applied to its affiliated group. If you are a MEDITECH EHR user and would like to voluntarily report to the MVP framework, MEDITECH would like to hear from you: you can respond to a survey via their form here. 

Traditional MIPS

For 2024 MIPS reporting, the MIPS score will continue to be based on the four performance categories and their corresponding weights. CMS did not finalize a performance threshold of 82 points, the mean of final scores from the 2017 through 2019 MIPS performance periods. Instead, the performance threshold will remain at 75 points for the 2024 performance period.

The table below summarizes a comparison of the MIPS point adjustments between the 2023 and 2024 performance periods:

Quality

For the 2024 performance period, CMS finalized changes to the quality measures inventory resulting in a total of 198 quality measures (this does not include QCDR measures which are approved outside of the rulemaking process).

• Addition of 11 quality measures (see Table Group A of Appendix A in the Final Rule)
• Removal of 11 quality measures (see Table Group C of Appendix 1 in the Final Rule)
• Partial removal of 3 quality measures from the MIPS quality inventory – these measures are removed from traditional MIPS but retained for MVPS (Table Group CC of Appendix 1 in the Final Rule)
• Substantive changes to 59 existing quality measures (see Table Group D of Appendix 1 in the Final Rule)

CMS also finalized the following measure proposals with modification:

• Addition of 1 new measure with a 1-year delay to the 2025 performance period: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level).
• Removal of 1 measure with 1-year delay to the 2025 performance period: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques

For the 2024 and 2025 performance periods, the data completeness threshold was previously finalized at 75% for eCQMs, MIPS CQMs, Medicare Part B claims measures, and QCDR measures. CMS finalized a data completeness threshold of 75%  for the 2026 performance period. CMS did not finalize increasing the performance threshold for 2027 in this rule.

CMS finalized modifying the criteria used to assess ICD-10 coding updates by:

• eliminating the automatic 10% threshold of coding changes that triggers measure suppression or truncation
• assessing the impact of coding changes to see if they affect the scope or intent of a measure, and
• assessing each collection type of a given measure separately to determine the course of action for a measure affected by an ICD-10 coding update.

Cost

A MIPS eligible clinician that demonstrates improvement in performance in the current MIPS performance period compared to their performance in the immediately preceding MIPS performance period qualifies for a cost improvement score. CMS finalized that the maximum cost improvement score available for the CY 2022 performance period/2024 MIPS payment year will be 0 percentage points, instead of the 1 percentage point out of 100 that was finalized in prior year rulemaking. However, beginning with the CY 2023 performance period/2025 MIPS payment year, CMS finalized that the maximum cost improvement score available will be 1 out of 100 percentage points.

Beginning with the 2024 performance period, CMS finalized the addition of 5 new episode-based cost measures and the removal of one measure. The new measures, each with a 20-episode case minimum are:

• An acute inpatient medical condition measure (Psychoses and Related Conditions)
• Three chronic condition measures (Depression, Heart Failure, and Low Back Pain)
• A measure focusing on care provided in the emergency department setting (Emergency Medicine)

CMS has finalized the removal of the Simple Pneumonia with Hospitalization measure beginning with the CY 2024 performance period/2026 MIPS payment year. There are a total of 29 cost measures available beginning with the 2024 performance period (see Table 53 in the Final Rule).

Improvement Activities

For the 2024 performance period, CMS finalized the addition of 5 new improvement activities, modification of 1 existing improvement activity, and the removal of 3 existing improvement activities (see Tables A, B, C respectively in Appendix 2 in the Final Rule). There are a total of 106 improvement activities in the MIPS inventory for the 2024 performance period. These new changes focus on areas such as HIV Prevention and behavioral/mental health.

Promoting Interoperability

CMS finalized the continuation of automatic reweighting for clinical social workers in the 2024 performance period. CMS did not propose to continue automatic reweighting for physical therapists, occupational therapists, qualified speech-language pathologists, clinical psychologists, and registered dietitians or nutrition professionals for the 2024 performance period. These clinician types will not be automatically reweighted beginning with the 2024 performance period.

CMS finalized increasing the performance period to a minimum of 180 continuous days within the calendar year, to align with the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals.

CMS modified the second exclusion within the Query of the PDMP measure. CMS changed the exclusion from: Any MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the performance period to Any MIPS eligible clinician who does not electronically prescribe any Schedule II opioids or Schedule III or IV drugs during the performance period.

CMS finalized requiring a “yes” response for the SAFER Guide measure beginning with the CY 2024 performance period. Prior to 2024, a “yes” or “no” response was accepted.

Certified EHR Technology

For the Quality Payment Program and the Medicare Promoting Interoperability Program, CMS moved away from “edition” construct for certification criteria (i.e.  2015 Edition Cures Update) and instead all certification criteria will be maintained and updated at 45 CFR 170.315.

Health IT Vendors

CMS finalized the elimination of the health IT vendor category beginning with the CY 2025 performance category. Health IT vendors are still able to participate in MIPS as third-party intermediaries by self-nominating to become a qualified registry or QCDR or continue to work with clinicians through the sale and support of health IT that allows the clinician or group to submit the data.

Targeted Review

CMS finalized opening the targeted review submission period on the day they release MIPS final scores and keeping it open for 30 days after MIPS payment adjustments are released. CMS also finalized that if they request additional information, it must be received by CMS within 15 days of the request. This would allow CMS to finalize scores by October 1.

If you have questions or need help with your MIPS/MVP reporting, please contact us.