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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 has proposed 5 new MVPs, along with revisions to all previously finalized MVPs.
The 5 newly proposed 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 is proposing to clarify that beginning with the 2023 performance period, subgroups reporting an MVP would receive their affiliated group’s complex patient bonus, if available. Further, CMS is proposing that subgroups would only receive reweighting based on any reweighting applied to its affiliated group.
Traditional MIPS
For 2024 MIPS reporting, the MIPS score will continue to be based on the four performance categories and their corresponding weights. CMS is proposing a performance threshold of 82 points, the mean of final scores from the 2017 through 2019 MIPS performance periods.
Quality
For the 2024 performance period, CMS is proposing changes to the quality measures inventory resulting in a total of 200 quality measures (this does not include QCDR measures which are approved outside of the rulemaking process).
- Addition of 14 quality measures
- Removal of 12 quality measures
- Partial removal of 3 quality measures from the MIPS quality inventory
- Substantive changes to 59 existing quality measures
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. For the 2026 performance period, CMS is proposing a data completeness threshold of 75% and for the 2027 performance period, a data completeness threshold of 80%.
CMS is also proposing the modify 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
CMS is proposing 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 previously finalized. However, beginning with the CY 2023 performance period/2025 MIPS payment year, CMS is proposing that the maximum cost improvement score available will be 1 out of 100 percentage points.
Beginning with the 2024 performance period, CMS is also proposing to add 5 new episode-based cost measures and to remove 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 is also proposing to remove the Simple Pneumonia with Hospitalization measure beginning with the CY 2024 performance period/2026 MIPS payment year. If these proposals are finalized, there would be a total of 29 cost measures available beginning with the 2024 performance period.
Improvement Activities
CMS is proposing to add 5 new improvement activities, modify 1 existing improvement activity, and remove 3 existing improvement activities. If finalized, there will be a total of 106 improvement activities in the MIPS inventory. These new changes will focus on areas such as HIV Prevention and behavioral/mental health.
Promoting Interoperability
CMS is proposing to continue 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.
CMS is proposing to increase the performance period to a minimum of 180 continuous days within the calendar year, to continue the alignment with the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals.
CMS is proposing to modify the second exclusion within the Query of the PDMP measure. CMS is proposing to change 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 is proposing to require a “yes” response for the SAFER Guide measure beginning with the CY 2024 performance period.
Certified EHR Technology
For the Quality Payment Program and the Medicare Promoting Interoperability Program, CMS is proposing to move 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 is proposing to eliminate the health IT vendor category beginning with the CY 2025 performance category. Health IT vendors would still be 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 is proposing to open the targeted review submission period on the day they release MIPS final scores and to keep it open for 30 days after MIPS payment adjustments are released. CMS is also proposing 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.
Should you have questions or need help with your MIPS/MVPs reporting, please contact us.