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2024 QPP Proposed Rule

Proposed updates to MIPS thresholds, cost measures, and Promoting Interoperability

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TL/DR

The CY 2024 QPP Proposed Rule introduces updates across MIPS categories and continues expanding the MVP framework.

  • Performance threshold proposed at 82 points (mean of 2017-2019 final scores); 200 quality measures with 14 additions and 12 removals
  • Five new MVPs proposed, including Women's Health and Mental Health/Substance Use Disorders
  • Five new episode-based cost measures added (Psychoses, Depression, Heart Failure, Low Back Pain, Emergency Medicine); Simple Pneumonia removed
  • PI minimum reporting period increased to 180 continuous days; SAFER Guide attestation required starting CY 2024

CMS proposed an 82-point threshold, five new MVPs, five new cost measures, and expanded PI requirements for the 2024 QPP.

Article content

CMS recently published the CY 2024 Quality Payment Program (QPP) Proposed Rule which included numerous updates to MIPS Value Pathways (MVPs) and Merit-based Incentive Payment System (MIPS). For the full text, 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 proposed 5 new MVPs along with revisions to all previously finalized MVPs:

  • 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

Traditional MIPS

For 2024, CMS proposes a performance threshold of 82 points, the mean of final scores from the 2017 through 2019 performance periods.

Quality

CMS proposes changes resulting in a total of 200 quality measures: addition of 14, removal of 12, partial removal of 3, and substantive changes to 59 existing measures.

For 2024 and 2025 performance periods, the data completeness threshold was previously finalized at 75%. For 2026, CMS proposes 75% and for 2027, 80%.

Cost

CMS proposes adding 5 new episode-based cost measures and removing one:

  • Psychoses and Related Conditions (acute inpatient)
  • Depression (chronic condition)
  • Heart Failure (chronic condition)
  • Low Back Pain (chronic condition)
  • Emergency Medicine (emergency department)

CMS proposes to remove Simple Pneumonia with Hospitalization, resulting in 29 total cost measures.

Improvement Activities

CMS proposes adding 5 new improvement activities, modifying 1, and removing 3, resulting in a total of 106 in the MIPS inventory. New activities focus on HIV Prevention and behavioral/mental health.

Promoting Interoperability

CMS proposes increasing the performance period to a minimum of 180 continuous days within the calendar year.

CMS proposes modifying the PDMP measure exclusion from clinicians writing fewer than 100 permissible prescriptions to clinicians who do not electronically prescribe any Schedule II opioids or Schedule III or IV drugs.

CMS proposes requiring a "yes" response for the SAFER Guide measure beginning with CY 2024.

Certified EHR Technology

CMS proposes moving away from the "edition" construct for certification criteria (i.e. 2015 Edition Cures Update). Instead, all certification criteria will be maintained and updated at 45 CFR 170.315.

Health IT Vendors

CMS proposes eliminating the health IT vendor category beginning with CY 2025. Health IT vendors would still be able to participate by self-nominating as a qualified registry or QCDR.

Targeted Review

CMS proposes opening the targeted review submission period on the day they release MIPS final scores and keeping it open for 30 days after payment adjustments are released. If additional information is requested, it must be received within 15 days.

For MIPS/MVPs reporting questions, please contact us.