MIPS 2023: Just the Facts

The MIPS rules for 2023 have been set. The overall point thresholds remain the same but, as usual, nearly every category has important updates. Here's what you need to know overall and in each category: Quality, Improvement Activities (IA), Promoting Interoperability (PI), and Cost.

Overall

The program makeup for MIPS remains the same as in 2023. The 100 program points break down with: 

• 30% from Quality 

• 30% from Cost 

• 15% from Improvement Activities

• 25% from Promoting Interoperability 

The rule keeps a minimum performance threshold of 75 MIPS points for the 2023 performance year. This means clinicians and groups must reach 75 MIPS points again in 2023 to avoid a negative payment adjustment in the 2025 payment year. The payment range is set to remain budget neutral with a -9% for total lack of participation and up to +9% as a maximum payment adjustment. Also, in 2023 the exceptional performance bonus pool funds are no longer in place.

Quality

Data completeness for this category remains at 70%. CMS has finalized 198 quality measures for the 2023 MIPS performance period. This reflects nine new measures, including one administrative claims measure, one composite measure, five high-priority measures, and two patient-reported outcomes measures. A couple of notable new measures include Psoriasis and Dermatitis.

Substantive changes have been made to 76 measures. High-priority measures now include health equity-related quality measures. CMS has removed 11 measures - including Biopsy follow-up for dermatology! The Quality category has also had partial removal of 2 measures that have been utilized heavily in the past. These include preventive care measures for Influenza and Pneumococcal vaccinations.

Promoting Interoperability

CMS will continue to automatically re-weight the Promoting Interoperability performance category and more heavily weight the Improvement Activities performance category for small practices; those with fewer than 15 eligible clinicians. When both Cost and Promoting Interoperability are re-weighted, Quality and Improvement Activities will each be weighted at 50%.

Electronic prescribing objective's Query of Prescription Drug Monitoring Program (PDMP) measure is REQUIRED while maintaining the associated points at 10 points. CMS is also expanding the Query of PDMP measure to include not only Schedule II opioids, but also Schedule III and IV drugs.

There is a modification to the options for active engagement for the Public Health and Clinical Data Exchange Objective measures. CMS is combining previous options for "active engagement" into a single option titled “Pre-production and Validation” and renaming the previous 3rd option to “Validated Data Production” for a total of 2 options. In addition to requiring a yes/no response for the required Public Health and Clinical Data Exchange measures, CMS also requires MIPS-eligible clinicians to submit their level of active engagement.

CMS is discontinuing automatic re-weighting for the following clinician types beginning with the 2023 performance period:

• Nurse practitioners

• Physician assistants

• Certified registered nurse anesthetists 

• Clinical nurse specialist

CMS will continue automatic re-weighting for the following in the 2023 performance period:

• Clinical social workers

• Physical therapists

• Occupational therapists

• Qualified speech-language pathologists

• Qualified audiologists

• Clinical psychologists, and 

• Registered dieticians or nutrition professionals

Improvement Activities

Adding 4 new Activities:

1. Adopt Certified Health Information Technology for Security Tags for Electronic Health Record Data

2. Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients

3. Create and Implement a Language Access Plan

4. COVID-19 Vaccine Achievement for Practice Staff

IA has also modified 5 Activities.

Removing 6 Activities:

1. Participation in a QCDR, that promotes the use of patient engagement tools

2. Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive

3. Use of QCDR for feedback reports that incorporate population health

4. Consultation of the Prescription Drug Monitoring Program

5. Leadership engagement in regular guidance and demonstrated commitment to implementing practice improvement changes

6. PCI Bleeding Campaign

Cost

CMS established a maximum cost improvement score of 1 percentage point out of 100 percentage points available for the cost performance category starting with the CY 2022 performance period/2024 MIPS payment year.

Want to Know More?

For more help with MIPS in 2023 contact us to sign up for monthly service. You get someone who will operate like a fractional employee to handle MIPS for you. With a dedicated MIPS expert to help you understand how to select the right measures, keep up with your performance, report the data, and keep you audit-proof, you can avoid the steep 9% penalty and work on hacking into those incentive dollars!