2027 Medicare Physician Fee Schedule (PFS) Proposed Rule

CMS recently published the CY 2027 Physician Fee Schedule (PFS) Proposed Rule which included proposals for the Quality Payment Program(QPP). CMS proposed updates to the Merit-based Incentive Payment System (MIPS) and MIPS Value Pathways (MVPs). For the full text of the rule, see the Federal Register.

‍Traditional MIPS

 Quality

For the 2027 performance period, CMS is proposing changes to the quality measures inventory resulting in a total of 180 quality measures (177 are available in traditional MIPS and 3 are available only for utilization in MVPs).

·       Addition of 2 quality measures that focus on prevention and chronic disease management (1 is proposed with a 1-year implementation delay to the CY 2028 performance period)

·       Adoption of 4 current QCDR measures as MIPS CQMs

·       Replacement of 7 existing, functional improvement MIPS measures with 5 functional outcome measures for orthopedic patients. The 5 new measures are currently QCDR measures that are being proposed as MIPS CQMs.

·       Removal of 20 quality measures

·       Substantive changes to 43 existing measures

 Beginning with the CY 2027 performance period, CMS is proposing to remove the high-priority designation for quality measures. In addition, CMS is proposing to remove the requirement that MIPS eligible clinicians report at least one outcome measure as one of their required measures, or a high-priority measure if an applicable outcome measure isn’t available. Instead of reporting an outcome measure (or high-priority measure),CMS is proposing that MIPS eligible clinicians would be required to report a MIPS core measure as 1 of their 6 quality measures. If a clinician, group, virtual group, subgroup or APM entity does not have an applicable MIPS core measure available to report, the clinician would be required to attest there wasn’t an applicable MIPS core measure for them to report and would choose another measure to report in place of the MIPS core measure. Clinicians who fail to report a core measure or complete the self-attestation will receive zero achievement points for that measure.  Small practices would be exempt from the MIPS core measure requirement and the self-attestation process.

 CMS is proposing that beginning with the CY 2027 performance period, topped out MIPS core measures subject to the 7-point scoring cap would no longer be subject to that cap and would instead be scored according to the defined topped out measure benchmark with a 10-point maximum.

 Cost

There are no proposals to the cost measure inventory for the CY 2027 performance period.

 Improvement Activities

For the CY 2027 performance period, CMS is proposing the following updates to the improvement activities inventory:

·       Addition of 6 new activities

·       Modification of 5 existing activities

·       Removal of 11 activities

 Promoting Interoperability

CMS is proposing to update the definition of CEHRT for the Medicare PI Program based on updates proposed by the Office of the National Coordinator for Health IT (ONC). Specifically, CMS is proposing to remove the certification criteria for “family health history”, “patient health information capture”, “automated numerator recording”, and “automated measure calculation ”effective January 1, 2027.  CMS is also proposing to remove ONC Direct Review and ONC-Authorized Certification Body(ONC-ACB) Surveillance attestations beginning with the CY 2026 performance period. Also, beginning with CY 2027 performance period, CMS is proposing to remove the Security Risk Analysis measure.

 CMS is proposing to modify the Electronic Prior Authorization measure. For the CY 2027 performance period, CMS is proposing that hospitals use CEHRT that includes health IT certified to at least one of the three ONC electronic prior authorization criteria to complete at least one prior authorization request for a medical item or service, excluding drugs. Then, beginning with the CY 2028 performance period, CMS is proposing that hospitals would be required to use CEHRT that includes health IT certified to all three ONC electronic prior authorization criteria. CMS is proposing to make the Electronic Prior Authorization measure optional and eligible for 10 bonus points for the CY 2027 performance period and then mandatory beginning with the CY 2028 performance period. A MIPS eligible clinician would be required to attest “Yes” or claim an applicable exclusion, but the measure would not be scored.

 Lastly, CMS is proposing a new measure, Electronic Prior Authorization for Prescription Drugs Measure, starting with the CY 2028performance period. This measure would fall under the Health Information Exchange objective and require the use of specific health IT modules within CEHRT to complete at least one prior authorization request for prescription drugs and medications. A MIPS eligible clinician would be required to attest “Yes” or claim an applicable exclusion, but the measure would not be scored.

 MIPS Value Pathways (MVPs)

 CMS is proposing to sunset the traditional MIPS reporting option after the CY 2028 performance period. Beginning with CY 2029 performance period, MVPS would be the only MIPS reporting option for MIPS eligible clinicians that do not participate in a MIPS Alternative Payment Model (APM).

 For the CY 2027 performance period, CMS is proposing to add 3 new MVPs to the MVP inventory: Diabetic Disease, Hypertension, and Hospitalist. CMS is also proposing to modify all 27 existing MVPs. Also, CMS is proposing that virtual groups would be able to report an MVP beginning with the CY 2029 performance period. Under CMS’ proposal to remove the outcome or high-priority measure requirement, clinicians participating in an MVP would instead be required to report at least one MIPS core measure as part of their four selected quality measures.

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