01/31/2024

TPMA Footnotes - February

MIPS Update

The Merit-Based Incentive Payment System (MIPS) has undergone significant changes for physicians. It is essential to assess the current state of the program as you navigate your 2024 reporting strategy. Here's a breakdown of what MIPS is, how it operates, why participation matters, and the recent updates:

What Is MIPS?
MIPS, established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), is a program that determines Medicare payment adjustments for eligible clinicians (ECs). By applying a composite performance score, ECs receive a payment bonus, penalty, or no adjustment. Launched in 2017, MIPS aims to shift the healthcare industry from fee-for-service to a pay-for-value model, reducing administrative burdens on ECs and instilling confidence in their annual payment updates.

The Quality Payment Program (QPP)
MIPS, a component of the QPP, consolidates three previous Medicare programs—Physician Quality Reporting System (PQRS), Value-Based Payment Modifier Program (VM), and Medicare Electronic Health Record Incentive Program (EHR)—into one comprehensive system. In a healthcare context, MIPS stands for Merit-Based Incentive Payment System, representing CMS's original reporting option for clinicians eligible to receive MIPS payment.

How Does MIPS Work?
MIPS operates as a 100 performance-based points program, calculating each Medicare Part B clinician's composite performance score (CPS). The four parameters for MIPS scoring and their respective category weights include:

• Quality (30%)
• Promoting Interoperability (25%)
• Improvement Activities (15%)
• Cost (30%)

Why Should You Care About MIPS?
Medicare Part B ECs are obligated to participate in MIPS or face a negative 9% payment adjustment on their Medicare Part B reimbursements. Despite a decrease in provider engagement from 97% to 90% in the past year, penalties may be imposed by government regulations or other providers. Additionally, MIPS scores are published on physician compare websites, emphasizing the importance of early engagement for practices new to MIPS to mitigate the risk of penalties.

2024 MIPS Changes:
In the final 2024 rule, a significant decision was made not to increase the penalty threshold to 82; it remains at 75, eliciting positive responses from ECs. The scoring system and measurement of scores and points remain unchanged. Quality reporting maintains a 12-month period, with an increased data completeness threshold from 70% to 75%. Notably, future rule changes propose modifying the threshold to 80% in 2026 and 2027. The 2024 updates include 198 available quality measures, with 13 new measures, 11 removals, and 59 modifications.

2024 Quality Updates:
In 2024, the reporting period for the Quality Category remains at 12 months, featuring six quality measures, including one high-priority measure. Notably, the data completeness threshold is raised from 70% to 75% in the final 2024 rule. To ensure compliance and maximize points for each quality measure, Eligible Clinicians (ECs) must report at least 75% of all eligible instances for the reporting year. Looking ahead, a proposed rule change for 2026 and 2027 suggests modifying the threshold to 80%. Moreover, there are noteworthy changes in the Quality Measures for 2024, with a total of 198 measures available. This includes the addition of 13 new measures, removal of 11, and modification of 59 measures. Three of the new measures are specifically relevant ONLY to retina specialists and no other specialty such as podiatry.

2024 Promoting Interoperability Adjustments:
After five years of the Merit-Based Incentive Payment System (MIPS), the final rule for 2024 extends the Promoting Interoperability (PI) category reporting period to 180 consecutive days, up from the initial 90 consecutive days. ECs are still required to meet the 2015 Electronic Health Record (EHR) Cures Act requirements for reporting in this category. Additionally, the Query of the Prescription Drug Monitoring Program and the Public Health and Clinical Data Registry for Electronic Case Reporting remain mandatory categories for 2024, rather than elective. A notable addition in the final rule is the introduction of a low-volume exclusion for providers who e-prescribe fewer than 100 Schedule II-IV medications. This exclusion was not available in the 2023 Final Rule. It's important to take note that, in the final rule for 2024 MIPS, completing the SAFER guides High Priority Assessment is now a requirement for reporting in the PI Category.

2024 Improvement Activities Adjustments:
The Improvement Activities (IA) reporting period remains at 90 consecutive days for the final 2024 rule. This rule introduces five new improvement activities while removing three from the list. Data Validation files for 2024 will necessitate careful review to ensure that ECs are accurately documenting the completion of the selected activities they attest to completing.

2024 Cost Adjustments:
In the 2024 final rule, the Cost category undergoes minimal changes that would significantly impact ECs. There has been substantial feedback and discussion about the 2022 cost scores, prompting the Centers for Medicare and Medicaid Services (CMS) to focus on improving data file content and providing a clearer explanation of how to utilize this data to enhance their cost scores.

Other Important Updates:
Promoting Interoperability reporting sees a reporting period increase to 180 consecutive days in 2024. A new low-volume exclusion is introduced for providers e-prescribing fewer than 100 Schedule II-IV medications. The final rule mandates completion of the SAFER guides High Priority Assessment for reporting the Promoting Interoperability Category. Improvement Activities reporting period remains at 90 consecutive days, introducing five new activities and removing three. Cost category changes have minimal impact, with a focus on improving data file content. Five new episode-based cost measures are added: Depression, Emergency Medicine, Heart Failure, Low Back Pain, and Psychoses and Related Conditions. MIPS Value Pathways (MVP) reporting requirements remain unchanged, offering practices the voluntary choice to participate.

In conclusion, whether your practice is new to MIPS or experienced, close attention to the 2024 changes is crucial. Actively participating and staying informed about the MIPS program, starting early, and regular check-ins are essential to avoid penalties and maximize incentives.