MIPS Reporting in 2023: Having More Options but Challenging

In the MIPS 2023 reporting period. We can see that the payment threshold is holding at 75 points.  Making it difficult to achieve the threshold score along with the changes in the 2023 program.

MIPS 2023 and The Changes 

With the release of the MIPS 2023 Final Rule. Centers for Medicaid and Medicare Services (CMS) finalize that most of the proposed changes occur in the proposed rule last July.

Few Challenges in MIPS 2023

  • All the Quality Measures that historically have high scores are removed from the program. There must be one question came into your mind that What does it mean? It will be hard to find out the Quality measures where you can easily achieve the full 10 points.
  • For the monitoring of the Cost performance category, no tools offer by the CMS during the performance year MIPS 2023. All the providers get according to the score of their performance related to the other providers respectively. The group the score will be around 15/30 points. It means that if any of the cost category measures apply to your reporting then you will not achieve 15 of your 100 points in your MIPS score.
  • MIPS Value Pathways (MVP) scoring is very challenging in MIPS 2023. Every MVP includes at least one population health measure applied to the score and then your team has no insight into what score it will be. It means that there’s less insight into your final score if you are reporting on MVP.
  • Because of the challenges of the various reporting options. “Simple” mechanisms, For Example, eCQMS from a certified electronic health record technology. CEHRT mays set up with providers to see a penalty. It means A provider or group must receive flawless scores for Promoting Interoperability (PI) and Improvement Activities (IA). In order to receive a score of 20/30 in the Quality category or an average of 7 points for each reported measure. Many providers will have to do this to find specialty measurements or work on performance improvement in their measures to reach the required level and avoid a penalty. An EHR or CEHRT reporting tool frequently does not provide this chance to assess and enhance.
  • There are so many options for reporting in MIPS 2023. Each of the options will most like to give a result of a different score. It means we suggest you, in the beginning, collect your data earlier and review the mid-year results to determine the optimal reporting part. For this, you need to focus to reach the best part.

MVP/ MIPS 2023 offers to focus on specialties and narrows the quality reporting requirement to only four measures.

Participation Options 

The participant in the MIPS 2023 – 2025 performance is as follows:

  • Sub-group
  • An Individual Clinician
  • Alternative Payment Model Entity
  • Single or Multi-specialty group

The specialty type is defined by using Medicare Part B claims. A multispecialty group comprises two or more specialty kinds, CMS establishes it by using  Medicare Part B claims, whereas a single-specialist group is described as a group that consists of one specialty type.

What Is Subgroup Reporting?

A subset of a group that has at least one MIPS-eligible doctor is referring as a subgroup, and it is identifiable by the group TIN, the subgroup identity, and the NPI of each eligible clinician. CMS is only allowing physicians who report through MVPs or the APM Performance Pathway to submit subgroup reports (APP). Subgroup reporting will be optional for the performance years 2023, 2024, and 2025. Starting in 2026, multispecialty groups will have to organize into subgroups to report MVPs.

The eligibility of clinicians planning to participate and register as a subgroup is defined by CMS utilizing the first 12-month period of the 24-month MIPS determination period. Subgroups would be subject to the connected group’s eligibility and special status considerations (identified by TIN). Above all due to implementation issues, CMS will not permit voluntary reports, opt-in eligible doctors, or virtual groups to submit MVPs for the MIPS 2023 performance year.




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