2023 QPP Final Rule

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 plans to move to MIPS Value Pathways (MVPs) to “improve value, reduce burden, inform patient choice in selecting clinicians, and reduce barriers to participation in Alternative Payment Models (APMs).” To that end, CMS has finalized 5 new MVPs and revised the 7 previously established MVPs that are available beginning with the 2023 performance year.

The 5 newly finalized MVPs for the 2023 performance year are:

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. While CMS previously finalized that a subgroup must provide a list of TIN/NPIs in the subgroup and a plain language name for the subgroup during registration, CMS finalized in this rulemaking that subgroups include a description of the composition of the subgroup. Further, CMS finalized that subgroups would be assigned the affiliated group’s score for the Foundational Layer measure, outcome-based administrative claims measures in the Quality category, and the Cost performance category. If a group score is not available, then the measure will be excluded from the subgroup’s final score. Lastly, for subgroups that register but don’t submit data as a subgroup, CMS will not assign a final score.

Traditional MIPS

For 2023 MIPS reporting, the MIPS score will continue to be based on the four performance categories and their corresponding weights. CMS finalized that the performance threshold will not change for the 2023 performance period and therefore, clinicians and groups must continue to reach a minimum of 75 points to avoid a negative payment adjustment in 2025.  

Furthermore, in 2023, clinicians will no longer have an additional threshold for exceptional performance bonus.

Quality

For the Quality category, CMS finalized a total of 198 measures for the 2023 performance period, which includes the addition of 9 quality measures, including 1 new administrative claims measure, 1 composite measure, 5 high priority measures, and 2 new patient-reported outcome measures.  Also, 11 quality measures were finalized for removal from the quality measure inventory and 2 measures were removed from the MIPS quality measure inventory but retained in MVPs.

CMS finalized that administrative claims measures will be scored using performance period benchmarks, while quality measures will continue to be scored using historical benchmarks.

For the 2023 performance year, CMS is maintaining the current data completeness requirement of 70%. However, for the 2024 and 2025 performance periods, CMS finalized increasing data completeness to 75%.

Improvement Activities

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

Promoting Interoperability

Beginning with the 2023 performance period, CMS finalized discontinuing automatic reweighting of the Promoting Interoperability (PI) category for nurse practitioners, physician assistants, certified registered nurse anesthetists, and clinical nurse specialists.  However, automatic reweighting will continue for the 2023 performance period for clinical social workers, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians and nutrition professionals.

CMS finalized allowing APM Entities to report PI data at the APM Entity Level when participating in MIPS at the APM Entity level. This is a change to how APM Entities had to report PI data at the individual or group level.

Prior to CY 2023 reporting, the Public Health and Clinical Data Exchange Objective includes 3 levels of active engagement. CMS finalized reducing the levels of engagement to 2 by combining Options 1 and 2 into a single option titled, “Pre-production and Validation” and renaming option 3 to “Validated Data Production.” In addition to requiring a yes/no attestation for the required measures under this objective, CMS now requires the submission of level of active engagement. Beginning with CY 2024 performance period, CMS finalized that MIPS eligible clinicians may spend only one performance period at the Preproduction and Validation level of active engagement per measure, and they must progress to the Validated Data Production level in the next performance period for which they report that measure.

The Query of the Prescription Drug Monitoring Program (PDMP) has been an optional measure for bonus points, but CMS finalized making it required beginning with the 2023 performance period worth 10 points, with exclusions available. CMS has also expanded the scope of the measure to not only include Schedule II but also Schedules III and IV drugs.

CMS finalized a 3^rd option for the HIE Objective for the 2023 performance period, Participation in the Trusted Exchange Framework and Common Agreement (TEFCA). MIPS Eligible clinicians would be required to attest Yes to being a signatory to a Framework Agreement as that term is defined by the Common Agreement for Nationwide Health Information Interoperability as published in the Federal Register and on the Office of the National Coordinator for Health Information Technology (ONC) website and use CEHRT to exchange information under this Agreement.

Beginning with 2023 performance period, CMS has finalized the following maximum points for the PI measures.

Cost

Beginning with the 2022 performance period, CMS finalized a maximum cost improvement score of 1 percentage point out of 100 percentage points available for the cost performance category. However, for the 2022 performance period, MIPS eligible clinicians will receive a cost improvement score of zero percentage points because CMS did not calculate cost measure scores for the 2021 performance period.

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