2024 Proposed Program Changes & What They Could Mean for You
The Centers for Medicare and Medicaid Services (CMS) recently dropped a critical document - the proposed rule for the 2024 Merit-based Incentive Payment System (MIPS). This comes as part of the CMS's seventh year of the Quality Payment Program and is packed with updates set to enhance continuous improvement in clinician performance and healthcare quality.
KEY CHANGES AND THEIR SIGNIFICANCE
1. Eligibility: Who's In, Who's Out
The proposed rule leaves MIPS eligibility mostly unchanged. If you're part of a vast array of healthcare professionals - from physicians to certified nurse midwives - you're still included. The low-volume threshold criteria remains the same as well: $90K in allowable charge AND 200 patients AND 200 services. As usual there's a carve-out, for those new to Medicare in 2023 and Qualifying APM Participants (QP) or Partial QPs.
2. Revamped Score Thresholds
Prepare for a threshold increase in the CY 2024 performance period/2026 MIPS payment year. CMS proposes 82 points, a 7 point hike! This means you'll need to hit 82/100 for a neutral adjustment. The overall score makeup remains the same: 30% Quality, 30% Cost, 15% Improvement Activities, and 25% Promoting Interoperability. Time to amp up your MIPS game to protect your revenue!
3. Quality: More Refined & Meaningful Participation
In a bid to make participation more meaningful, CMS aims to refine Quality measures. As usual, there are lots of measure changes - a proposal to add 14 new MIPS quality measures, remove 12 MIPS quality measures, partially remove 3 MIPS quality measures that are proposed for removal from traditional MIPS and proposed for retention for use in MVPs, and make substantive updates to 59 MIPS quality measures They propose an expanded definition of the collection type, new data submission criteria for eCQMs, and a data completeness criteria threshold that maintains at least 75 percent for the CY 2026 performance period/2028 MIPS payment year, eventually increasing to at least 80 percent for the CY 2027 performance period/2029 MIPS payment year. Expect to see a measure set inventory of 200 MIPS quality measures and a shake-up of speciality sets for measure additions and removals!
4. Promoting Interoperability: Longer Reporting Period
CMS proposes to lengthen the performance period from 90 to 180 continuous days, providing a technical update to the e-Prescribing measure's description and modifying the Safety Assurance Factors for Electronic Health Record Resilience (SAFER) Guide measure. The Office of the National Coordinator for Health Information Technology (ONC) will also cease the "year" criteria for CEHRT, maintaining a single set of criteria standards ongoingly.
5. Improvement Activities: Refining & Updating Inventory
Proposed changes include the addition of five new activities, modifications to one, and removal of three existing activities. New additions focus on areas like HIV prevention, behavioral/mental health, and the use of computable guidelines and clinical decision support.
6. Cost: More Episode-Based Measures
CMS plans to add five new episode-based measures in areas like depression, emergency medicine, and low back pain. They also propose a 20-episode case minimum for each new measure. Notably, the Simple Pneumonia with Hospitalization episode-based measure will be removed from the CY 2024 performance period/2026 MIPS payment year.
7. MVPs: New Additions and Consolidations
Five new MIPS Value Pathways (MVPs) will be introduced, focusing on areas like women's health, infectious disease prevention, and mental health. Some old MVPs will be consolidated into a singular group known as the "Adult Universal Core Set".
8. Targeted Reviews: Expanded Eligibility
CMS proposes to add virtual groups and subgroups to those eligible to submit a request for targeted review, alongside modifications to the timeline and requirements for this review.
9. Subgroup Reporting Changes
Subgroup reporting will see some changes too. For example, an MVP participant that is a subgroup will receive the same reweighting as its affiliated group. There were several items CMS notes they previously overlooked in regulatory, reporting, facility-based scoring and more for subgroups but they are ready to make these corrections and acknowledge the oversights.
10. Payment Adjustment: More Losers and Bigger Winners
As you may know, the maximum penalty for doing absolutely nothing remains at a -9% adjustment! The CMS proposed policies are expected to increase the number of clinicians receiving a negative adjustment from 36.75 percent of eligible clinicians to 54.31 percent of eligible clinicians, but decrease the average negative adjustment from -2.89 percent to -2.40 percent. This is because the increased performance threshold will cause many clinicians who previously scored slightly above the performance threshold to now score slightly below the performance threshold, shifting their expected payment from a small positive adjustment to a small negative adjustment. Since MIPS is a zero sum game for CMS, the increase in the number of clinicians receiving a negative score will contribute to an increase in the size of the budgetary dollars available to fund incentives. The proposed rule reflects that the maximum positive payment adjustment is +8.82 percent in the proposed rule model. This means that the case to do well is now stronger than ever!
Have Some thoughts on the rule?
Comments, including mass comment submissions, can be completed electronically. To be assured consideration, comments must be received at one of the addresses provided below, no later than 5pm on September 11, 2023. You may submit electronic comments on this regulation to http://www.regulations.gov - follow the “Submit a Comment” instructions. CMS uses this feedback to help further their own understanding of what is proposed and ultimately finalized so don’t hesitate to remark on any aspect or item within the rule!
Brace for Impact
All in all, some or all of these proposed changes will shake up the landscape of the MIPS program in 2024. To stay on top of the game, it's essential to understand these changes and plan ahead. Whether you're a high-performing clinician or a third-party intermediary, the time is now to prepare for these changes and continue to improve the quality of healthcare services provided to Medicare beneficiaries and other patients. This is your call to action. Time to be a healthcare rockstar!
If you need a partner to help take over MIPS in your practice, Chirpy Bird can help. Give us a call today to help improve your 2023 score and be prepared with a MIPS expert in 2024!
