[Note: P3 Care, as a MIPS-qualified registry, presents your series of blogs on MIPS final rule updates for CY 2023. So, this is the ‘Part II’ of our CY 2024 MIPS policy changes.]
The PFS final rule for MIPS reporting is the provider’s compass for navigating safely. So, we have the MIPS 2024 final rule, and providers need to understand everything in it. In ‘Part I’ of our blog series, we delineated the rules and parameters for the quality and cost categories. We covered the critical aspects, from quality measures to the data completeness threshold to cost scoring.
In this blog, we will cover the details related to the two remaining MIPS performance categories: PI and Improvement Activities. Together, these categories exemplify a dual commitment to a better patient experience. The policies under these categories foster technological advancements and drive improvements across the healthcare spectrum.
So, without further ado, roll down the policy updates regarding these two categories. It will help us to revise our MIPS strategies for the coming fiscal year 2024 to stay safe from up to 9% penalties.
Improvement Activities Performance Category
IA Measure Inventory
After several additions, removals, or modifications, the PFS final rule presents the IA measure inventory. Overall, the new MIPS inventory has 106 improvement activities that have not been finalized yet.
- Collectively, there are 5 more IAs added to the list, enclosing an MVP-specific activity. The title for this new IA is ‘“Practice-Wide Quality Improvement in MVPs’.
- Meanwhile, CMS has permanently removed 3 improvement activities, whereas 1 got a modification.
Promoting Interoperability Performance Category
The Criteria for Certified EHR Technology (CEHRT)
The new rule also updates the criteria for the use of CEHRT in the healthcare system. So, there is no longer a need to bind with the 21st Century Cures Update of health IT certification criteria. For MIPS 2024, health IT must align with ONC’s regulations. Therefore, going away from the ‘2015 course edition’ criterion, CMS will update new criteria at CFR 170.315. So, for PY 2024, MIPS participants must use and implement CEHRT that fulfills the definitions and requirements that ONC currently has and may adopt in the future.
CEHRT Threshold Policy for Shared Savings Program ACOs:
Medicare ACOs will not experience any change to the CEHRT threshold policy in this regard. Although CMS has proposed to modify the policy in future PY, CMS has held the decision for MIPS 2024.
According to the preset CEHRT threshold policy, ACOs in certain tracks need to confirm each year:
- Their participating clinicians use CEHRT for documenting and sharing patient information.
- Proportions for participating clinicians using CEHRT may vary for different tracks. E.g., for tracks A–D, 50% of clinicians must use CEHRT, and for tracks E and ENHANCED, it’s 75%.
Automatic Reweighting Policy
CMS has modified its automatic reweighting policy. Under this policy, some clinicians get the MIPS benefit of reweighting the PI category to 0% of the final score. However, the weight is redistributed among the remaining three categories of MIPS. For MIPS 2024 reporting, the rule announces the discontinuation of the following clinicians:
- Physical therapists
- Occupational therapists
- Qualified speech-language pathologists
- Clinical psychologists
- Registered dietitians / Nutrition professionals
Anyhow, good news for ‘Clinical Social Workers’, who will still get the advantage of PI category reweighting in MIPS. Likewise, automatic reweighting continues for clinicians and groups with the following special statuses:
- Ambulatory Surgical Center (ASC)-based
- Non-patient facing
- Small practice
Since FY 2024, the federal government has increased the length of the performance period. So, the performance period will consist of 180 continuous days within the calendar year. CMS has a strategic reason behind this modification. This modification allows the MIPS PI category to participate in the Medicare PI program for eligible hospitals and critical access hospitals.
Clinicians only need to certify their usage of the High Priority Practices SAFER Guide. They can do so with a “yes” response as part of the Measure Points requirement beginning with the CY 2024 performance period.
That’s all about the MIPS 2024 final policies for Promoting Interoperability and Improvement Activities Categories. For more details and guidance, you can ask for our MIPS consulting services. Place your queries and concerns in the comment section below. Our experts will answer them all to help you understand.