New Strategies and Purposes Behind MIPS 2024 Proposed Rulemaking

New Strategies and Purposes Behind MIPS 2024 Proposed Rulemaking

Going smoothly with the flow, the MIPS program is now moving towards MIPS 2024. Right now, the clinicians are participating in MIPS 2023. But alongside this, several proceedings from the past MIPS 2022 reporting are taking place.

For instance, the payment adjustments for PY 2022 will be done in the coming CY 2024. Recently, the CMS made available the final preview score period. Thereby, the MIPS participants can preview their scores. Although these scores are not final, there can be adjustments before final payment adjustments.

Similarly, the big news for 2023 MIPS participants is that they can apply for the MIPS Exception applications. The application window is open until 8 p.m. ET on January 2, 2024. Well, coming back to the MIPS 2024 rulemaking and the forwarded proposed rule. In this blog, we will simply discuss the strategies and precursors behind the new changes to MIPS rules.

MIPS 2024 Proposed Rulemaking

Whatever CMS does, it does it for some reason. Instead of making random decisions, it always analyzes the conditions precisely. Therefore, it accepts requests and complaints from the public. Thus, it proposes a favorable solution to overcome the problem. After forwarding the new proposal, it opens a comment period. During this period, clinicians and related individuals can again give their reviews. Also, CMS does consider the suggestions before making a final decision if they’re valuable.

Anyhow, CMS forwarded the PFS final role for MIPS 2024 on July 13. This rule involves information regarding the MIPS program’s upcoming changes. Although this is not a final rule, it will help clinicians rearrange their MIPS strategies. Now is the time to overview the purposeful motive supporting MIPS rulemaking for FY 2024. Before further delay, let’s just start it.

The End of PHE; Goodbye COVID-19!

COVID-19 appeared in the healthcare landscape like a nightmare for clinicians. It was so daunting for the providers to attend to such enormous patients all at once. They have to give quality care all at once, despite the quarantine and lockdown barriers.

Anyhow, the clinicians have showcased the best of their abilities throughout the pandemic. CMS has also responded to this public emergency and provided relaxation in MIPS. COVID-19 was truly a public health emergency (PHE). It took almost three years for clinicians to deal with the pandemic and its aftereffects. It proved to be overwhelming for the providers, as they faced many financial problems as well. So, from MIPS 2024 on, the CMS is ceasing this PHE and moving back to the QPP focus path. Therefore, CMS has given special consideration to the following in its MIPS 2024 proposed rulemaking:

  • New policies for the development and maintenance of MIPS MVPs
  • Utilization of digital measurement and health IT
  • The integrity of program data (safe, secure, and accurate data)
  • The potential return on investment

Development and Maintenance of MVPs – The Future of MIPS

The transition from MIPS to MVPs is not unknown to clinicians. Back in the day, CMS announced this, more specifically in the PFS final rule for PY 2023. For the safe shift, it has been considered MVPs as a voluntary reporting option this year. Well, for PY 2024, we have five newly proposed MVPs as follows:

  • Putting Women’s Health First
  • Providing High-Quality Care for Ear, Nose, and Throat Disorders
  • Management of Infectious Diseases (HIV and Hepatitis C)
  • Quality Care for Substance Use Disorders and Mental Health
  • Support for Musculoskeletal Rehabilitation

CMS proposes new updates to MVPs based on two things:

  1. MVP inclusion criteria
  2. Feedback from the MVP maintenance process

So, the future MVP update will depend on these two. CMS mainly wants to capture the aspects of specialist quality in Universal Foundation by doing so. Alongside this, CMS has proposed the consolidation of two previous MVPs. These are the Promoting Wellness and Optimizing Chronic Disease Management MVPs. They are intended to be considered a single primary care MVP. All these align the QPP inventory with quality measures in the adult core set of the Universal Foundation.

Medicare CQMs as a New Reporting Option for Medicare ACOs

The PFS rule for PY 2023 declared the sunset of CMS Web Interface as a collection type for MIPS. However, the proposed rule for PE 2024 has introduced a new collection type for MSSP ACOs. Now, they can participate in MIPS using CQMs under the APM Performance Pathway (APP). The purpose behind the creation of a novel collection type is quite meaningful. CMS wants to prepare ACOs for the all-payer/all-patient MIPS CQMs and eCQMs.

Promising the Integrity of Program Data

CMS has observed cases of inaccurate data submission on behalf of Health IT vendors. The lack of data validation requirements for these vendors is the reason behind this. Therefore, CMS has proposed the elimination of this distinct type of third-party intermediary from MIPS PY 2025. However, they will be able to participate in MIPS if they self-nominate themselves as QCDRs or MIPS-qualified registry members.

The Goal of Greater Return on Investment

As we know, CMS has the ideal goal of receiving greater returns on its investment. This investment is what they do in MIPS participation. Customarily, they give a positive payment adjustment on attaining the height scores. So, CMS has proposed a modest increase in the performance threshold for the three MIPS reporting options. The proposed performance threshold is 75 to 83 points.


Overall, as the MIPS program progresses towards MIPS 2024, clinicians should stay informed about new rule changes. It will help them adapt their strategies accordingly. Hang on to P3 Care for the latest news regarding MIPS. We as a MIPS-qualified registry, keep an eye on every move. Embrace the transition to MVPs for a more focused and impactful experience with our MIPS consulting services.

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