The MIPS is the finest opportunity for providers to make a real difference in their performance. Overall, CMS is trying to reshape the healthcare landscape using the MIPS reporting framework. We know that things do not remain the same. CMS always focuses on the quality of care delivery. Therefore, it sets milestones for practitioners to achieve. Once they achieve them, CMS immediately sets the next target, keeping the same motive. Every year, CMS does so and drops the PFS proposed rule for MIPS reporting. Recently, we got a proposed rule for MIPS 2024.

You know, what is the coolest part? You get to say something! It means that once the proposed rule is released, it initiates a commenting period. During this period, the related personnel and providers give feedback. Afterward, CMS closely looked at these suggestions before dropping the final PFS rule. The same is going to happen for MIPS 2024. Right now, we are in the MIPS 2024 proposed rule commenting period.

You might be thinking, What are the changes for MIPS 2024? CMS usually tweaks things like performance measures, scoring methods, and reporting requirements. Well, let’s get straight to the key changes proposed for MIPS 2024 reporting.

PFS Proposed Rule for MIPS 2024

On July 13, 2023, we got the detailed document from CMS on the official website of QPP. However, the commenting period is open until September 11, 2023. The rule has several significant modifications, which we will be mentioning and discussing below.

The Performance threshold rises to 82 points

The payment adjustment ratio was up to ±9% for MIPS 2023. And the rule proposes no change in it for the coming MIPS 2024. However, the most significant change is the increase in the performance threshold to 82 points. CMS plans to use the mean final scores from 2017–2019 to set it.

• All participants in MIPS 2024 have to score at least 85 points to stay neutral.
• If their final score falls below 85 points, they will get up to a -9% MIPS penalty.
• However, if they get more than 85 points, they will get up to +9% MIPS incentives.

MIPS Category Updates

Proposed Changes in the Quality Category

Data Completeness Requirement

As we know, data completeness is the major requirement for staying competitive in MIPS. Otherwise, you won’t be able to get MIPS incentives; instead, you might get a penalty for bad performance. For MIPS 2024, the data completeness threshold is 75 points for all the quality measures reported. It has a 5% increase from that finalized for MIPS 2023, i.e., 70%. Medicare CQMs will also be required to fulfill this requirement. For future performance years, the proposed rule suggests the following thresholds:

Measure Inventory

MIPS is throwing down a total of 200 quality measures. CMS has proposed 14 fresh ones, chopping off 12, keeping three for MVPs, and giving a facelift to 59 existing ones. You can see the details of these measures on QPP’s official website.

New Collection Type for Medicare ACOs

Medicare ACOs have faced aggregation and patient matching challenges in past years when reporting eCQMs and MIPS CQMs. Therefore, CMS has proposed Medicare CQMs, a new collection type for ACOs under the APP.

Proposed Changes in the Cost Category

Calculation and Scoring

CMS suggests calculating improvement scoring for the cost performance category at the category level without utilizing statistical significance beginning with the CY 2023 performance period/2025 MIPS payment year.

CMS’s proposals are great! They are recommending a maximum cost improvement score of one percentage point out of a possible 100 for the CY 2023 performance period/2025 MIPS payment year. Likewise, the highest possible cost improvement score for the CY 2022 performance period/2024 MIPS payment year will be 0 percentage points.

Measure Change

CMS introduces five newer episode-based cost measures for the 2024 performance period. These measures are Depression, Emergency Medicine, Heart Failure, Low Back Pain, and Psychoses and Related Conditions. Additionally, they plan to exclude simple Pneumonia with Hospitalization measures.

Proposed Changes in the Improvement Activities (IA) Category

For MIPS 2024, CMS has proposed Improvement Activities in the MIPS inventory. They contain five fresh measures. However, the three activities are required to be removed.

Proposed Changes in the Promoting Interoperability (PI) Category

Performance Period

The proposed MIPS 2024 rule suggests an expansion of the performance period length for the PI. Within a CY, it will lengthen from a minimum of 90 continuous days to a minimum of 180 continuous days.

CEHRT Definition

The “2015 Edition health IT certification criteria” require replacement with “ONC health IT certification criteria”.

CEHRT Use by APMs

75% of clinicians in APM entities needed to use CEHRT to be an Advanced APM. However, the threshold is proposed to be removed. For MIPS 2024, the APM must use CEHRT that goes with:

1. The Base EHR definition from the 2015 Edition or any later Base EHR definition;
2. Any such ONC health IT certification requirements that are found to be appropriate for the APM.

Automatic Reweighting

CMS has decided to reconsider the automatic reweighting for certain clinician types. The MIPS 2024 proposed rule depicts the continuation or discontinuation of reweighting for the following clinicians:

Measure Changes

CMS has proposed two major changes.

1. Firstly, it will require modification of the exclusion for the PDMP Measure. This step will support clinicians who don’t electronically prescribe Schedule II opioids and Schedule III and IV drugs during the performance period.
2. Secondly, from PY 2024 on, a “yes” response will be obligatory to fulfill the SAFER Guide measure.

Conclusion

Under the MIPS 2024 Proposed Rule, the Quality Payment Program has undergone significant changes. These changes will affect reporting in the traditional MIPS program, APM and ACO reporting, and the development of MVP reporting. Clinicians must begin reviewing these differences now. This will help them comprehend their potential impact on reporting practices for the next year. The Final Rule is anticipated to be published later this fall.

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