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2023 QPP Final Rule

Finalized updates to MIPS scoring, quality measures, and Promoting Interoperability

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TL/DR

The CY 2023 QPP Final Rule confirms updates across all MIPS performance categories and expands the MVP framework.

  • Five new MVPs finalized; 12 total available for 2023 performance year reporting
  • Performance threshold stays at 75 points; exceptional performance bonus eliminated for 2023
  • 198 quality measures finalized (9 added, 11 removed); data completeness remains 70% for 2023, rising to 75% for 2024-2025
  • PI changes: PDMP query required (10 points) for Schedules II-IV; active engagement levels reduced from 3 to 2; TEFCA added as HIE option

CMS finalized five new MVPs, a 75-point threshold with no exceptional performance bonus, and PI changes including required PDMP query.

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CMS recently published the CY 2023 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 finalized 5 new MVPs and revised the 7 previously established MVPs available beginning with the 2023 performance year:

  1. Advancing Cancer Care
  2. Optimal Care for Kidney Health
  3. Optimal Care for Patients with Episodic Neurological Conditions
  4. Supportive Care for Neurodegenerative Conditions
  5. Promoting Wellness

CMS also finalized changes for subgroup reporting to MVPs, including requirements for TIN/NPI lists, plain language names, and composition descriptions. Subgroups would receive affiliated group scores for Foundational Layer measures and outcome-based administrative claims measures.

Traditional MIPS

For 2023 MIPS reporting, the MIPS score continues to be based on the four performance categories and their corresponding weights. CMS finalized that clinicians and groups must continue to reach a minimum of 75 points to avoid a negative payment adjustment in 2025. Additionally, clinicians will no longer have an additional threshold for exceptional performance bonus in 2023.

MIPS performance categories and weightsMIPS scoring thresholds

Quality

CMS finalized a total of 198 measures for the 2023 performance period, adding 9 quality measures. 11 quality measures were finalized for removal, and 2 were removed from MIPS but retained in MVPs.

Quality measures additionsQuality measures removals

CMS finalized that administrative claims measures will be scored using performance period benchmarks, while quality measures continue using historical benchmarks. Data completeness remains at 70% for 2023, increasing to 75% for 2024 and 2025.

Improvement Activities

CMS finalized updates to the improvement activities inventory by adding 4 new, modifying 5, and removing 6.

Improvement activities additionsImprovement activities removals

Promoting Interoperability

Beginning with 2023, CMS finalized discontinuing automatic reweighting of PI for nurse practitioners, physician assistants, certified registered nurse anesthetists, and clinical nurse specialists.

CMS finalized reducing active engagement levels from 3 to 2 by combining Options 1 and 2 into "Pre-production and Validation" and renaming Option 3 to "Validated Data Production."

The Query of PDMP becomes required (10 points), expanded to include Schedules III and IV drugs. CMS finalized a 3rd option for the HIE Objective: Participation in TEFCA.

Maximum PI points for 2023

Cost

CMS finalized a maximum cost improvement score of 1 percentage point out of 100 percentage points for the cost performance category.

For MIPS/MVPs reporting questions, please contact us.