[Note: P3 Care, as a MIPS qualified registry, presents your series of blogs on MIPS final rule updates for CY 2023. So, this is ‘Part III’ of our CY 2024 MIPS policy changes.]
MIPS reporting rules and policies may vary from one reporting option to another. The PFS final rule for MIPS 2024 addresses the changes for all three reporting options briefly. If you’re a new reader, check out our blogs Part I and Part II on the MIPS 2024 reporting policy revisions. In the previous blogs, we’ve explained the modification under the four MIPS performance categories. In ‘Part III’, we will be discussing the final scoring policy updates, if any, in detail.
Now let’s dig in with a little introduction to MIPS Final Scores!
What is MIPS Final Scores?
Through the MIPS framework, CMS accesses the clinician’s performance in four categories. The participants get scores for reporting measures and activities under these categories. However, by combining the percentages from each category, CMS assigns MIPS final scores. Meanwhile, a total score out of 100 MIPS points impacts the Medicare Part B payment adjustments. In other words, it determines whether the adjustments will be +ve, -ve, or neutral in subsequent years.
The scoring for small practices or participants with special status may vary. Likewise, clinicians may apply for exception applications during the performance period. In such cases, CMS checks to see if the applicant is eligible for an exception. If they find them eligible, the percentage is redistributed, considering the percentage as zero for the applied category.
MIPS 2024 Policy Update for Final Scoring
Here are some policy updates finalized in the Physician Fee Schedule Final Rule for MIPS 2024.
This policy change is truly applicable to participants reporting MVPs. Subgroup reporting is a participation option in MIPS reporting via MVPs.
According to the old MIPS policy, clinicians participating as subgroups in MVPs get facility-based scores, if applicable. Anyhow, the policy for facility-based scoring at the subgroup level has been revised. As per MIPS 2024 policy, there will be no facility-based score calculation for clinicians at the subgroup level. Merely, this is so for two main reasons:
- The PFS final rule does not include any facility-based MVP.
- Facility-based scoring is only available for MIPS participants reporting via traditional MIPS. However, the subgroup level isn’t a participation option in this reporting option. Here, the facility-based clinician or group gets the scores as part of their final scores.
Remember, a clinician or group working within a facility may opt to report an MVP or APP. In this case, CMS will calculate a final score using facility-based measurement alongside another final score from MVP or APP reporting. Following that, CMS will award the higher of these final scores.
Complex Patient Bonus
Subgroups reporting via MVPs can now get their complex patient bonus, if available. Moving one step ahead, CMS declares the addition of § 414.1365(e)(4)(i) in the Code of Federal Regulation. CMS confirms that clinicians participating as a subgroup in PY 2023 will get their bonus if they qualify for it.
We all know that CMS has proposed to increase the performance threshold to 82 points. So, all clinicians were expecting that the final rule would implement this threshold. Although the implementation might be disappointing for themselves, it is even tougher to achieve. Anyhow, the MIPS 2024 final policy holds 75 points as a performance threshold. So, the new policy has reduced the MIPS reporting stress for clinicians to some extent.
Targeted Review Timeline
The timeline for target review will open just after CMS releases the MIPS final scores in MIPS 2024. The new policy doesn’t have any changes in this regard.
- The timeline will remain open until 30 days after the payment adjustments.
- Clinicians will have the opportunity to request a targeted review for 60 days.
- The period begins 30 days before the release of payment adjustments and continues after 30 days of adjustments.
- Let’s say the CMS vendor asks for any documentation during this period, then the receipts have to respond within 15 days.
The MIPS 2024 new policy encloses the final scoring policy modifications in detail. P3 Care, as a MIPS qualified registry, can help you understand the policies. We have covered everything related to final scoring policy changes in MIPS reporting. The subgroup category of MVPs is the center of attention for major modifications. So, clinicians participating as subgroups must give special attention. Get our MIPS consulting services to ease your passage into MIPS 2024.