2023 Medicare Physician Fee Schedule Final Rule for Quality Payment Program Published

On Nov. 1, 2022, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) Final Rule, which includes policy changes for the Quality Payment Program (QPP) for the 2023 performance year and beyond. The final rule contains policies regarding the development of new MIPS Value Pathways (MVPs) and refinement of subgroup participation, revisions to the quality measure and improvement activities inventories and other policies. Starting in 2023, clinicians will have three reporting options in the Merit-Based Incentive Payment System (MIPS):

1. MVPs;
2. Traditional MIPS; and
3. Alternative Payment Model (APM) Performance Pathway (APP).

Notably, the CMS plans to sunset traditional MIPS after the 2026 performance year. At that point, MVPs will become mandatory, except for clinicians who are eligible to report using the APP.

The ACR RISE registry staff reviewed the final rule and highlighted critical policy changes for the 2023 MIPS reporting period. You are also encouraged to check out the Preliminary Analysis of CY23 Medicare Physician Fee Schedule Final Rule and pay particular attention to any deletion of, or changes to, the measures for quality, promoting interoperability or improvement activities to ensure you are tracking the correct data during 2023. If you have questions or concerns about how these changes may affect your practice, contact RISE staff at [email protected].

Performance Category

Weights

There is no change in the performance category weights from performance year 2022 to 2023.

• Quality: 30% for PY 2023;
• Promoting Interoperability: 25% for PY 2023;
• Improvement Activities: 15% for PY 2023; and
• Cost: 30% for PY 2023.

Threshold

There is no change in the performance threshold from performance year 2022 to 2023. The performance threshold is set at 75 points for PY 2023.

As a reminder, the 2022 performance year/2024 payment year was the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.

Quality Performance Category

Quality Measures

The CMS finalized a total of 198 quality measures for the 2023 performance period. It is important to note that two measures in the ACR RISE Registry, QPP110, and QPP111, will no longer be reportable via traditional MIPS reporting for the 2023 performance period/2023 MIPS. Instead, these measures can be reported via the Advancing Rheumatology MVP for the 2023 performance period. 

Data Completeness

The CMS is increasing the data completeness threshold to 75% for the 2024 and 2025 performance periods. For the 2023 performance period, the data completeness threshold remains at 70% as finalized in the CY 2022 Physician Fee Schedule Final Rule.