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):
- MVPs;
- Traditional MIPS; and
- 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.
Quality Performance Category Collection Types
The CMS Web Interface will sunset as a collection type and submission type for traditional MIPS, beginning with the 2023 performance period. The CMS Web Interface will remain an available collection type only for Medicare Shared Savings Program Accountable Reporting Organizations reporting via the APP in the 2023 and 2024 performance periods.
Improvement Activities Performance Category
The CMS is:
- Adding four new improvement activities;
- Adopt certified health information technology for security tags for electronic health record data;
- Create and implement a plan to improve care for lesbian, gay, bisexual, transgender, and queer patients;
- Create and implement a language access plan; and
- COVID-19 vaccine achievement for practice staff.
- Modifying five current improvement activities; and
- Removing six current improvement activities.
The six improvement activities that will be removed for the 2023 performance year are:
- IA_BE_7: Participation in a QCDR, that promotes use of patient engagement tools;
- IA_BE_8: Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive;
- IA_PM_7: Use of QCDR for feedback reports that incorporate population health;
- IA_PSPA_6: Consultation of the Prescription Drug Monitoring Program;*
- IA_PSPA_20: Leadership engagement in regular guidance and demonstrated commitment for implementing practice improvement changes; and
- IA_PSPA_30: PCI Bleeding Campaign.
*Commonly reported by RISE registry users.
Promoting Interoperability (PI) Performance Category
Public Health and Clinical Data Exchange Objective
The CMS is modifying the options for active engagement for the Public Health and Clinical Data Exchange Objective measures.
Query of Prescription Drug Monitoring Program (PDMP) Measure
The CMS is making this a required measure beginning with the 2023 performance period.
Health Information Exchange (HIE) Objective
The CMS is keeping the two existing options for satisfying the HIE objective and adding a third option (Participation in the Trusted Exchange Framework and Common Agreement [TEFCA]) for the 2023 performance period.
PI Measure Points
The CMS adjusted the individual PI measures maximum points, beginning with the 2023 performance period.
PI Reweighting
The CMS is discontinuing automatic reweighting for the following clinician types, beginning with this 2023 performance period:
- Nurse practitioners;
- Physician assistants;
- Certified registered nurse anesthetists; and
- Clinical nurse specialists.
MIPS-eligible clinicians, groups and virtual groups with the following special statuses will continue to receive automatic reweighting:
- Ambulatory surgical center based
- Hospital based
- Non-patient facing
- Small practice
Cost Performance Category
The CMS is establishing a maximum cost improvement score of 1 percentage point out of 100 percentage points available for the cost performance category, starting with the 2022 performance period. It notes that all MIPS-eligible clinicians will receive a cost improvement score of zero percentage points for the 2022 performance period because cost measure scores were not calculated for the 2021 performance period. It is establishing this policy to adhere to the statutory requirement of accounting for improvement in the assessment of performance under the cost performance category.
MIPS Value Pathways (MVPs)
The CY 2023 PFS Final Rule finalized five new MVPs and made modifications to the seven previously finalized MVPs, including the Advancing Rheumatology Patient Care MVP. The table below lists the measures and activities that are finalized within the Advancing Rheumatology Patient Care MVP.
| Quality | Improvement Activities | Cost |
|
· Q111: Pneumococcal Vaccination Status for Older Adults
· Q130: Documentation of Current Medications in the Medical Record · Q134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan · Q176: Tuberculosis Screening Prior to First Course Biologic Therapy · Q177: Rheumatoid Arthritis (RA): Periodic Assessment of Disease Activity · Q178: Rheumatoid Arthritis (RA): Functional Status Assessment · Q180: Rheumatoid Arthritis (RA): Glucocorticoid Management · ACR12: Disease Activity Measurements for Patients with PsA · ACR14: Gout Serum Urate Target · ACR15: Safe Hydroxychloroquine Dosing |
· IA_AHE_3: Promote use of patient-reported outcome tools
· IA_BE_1: Use of certified EHR to capture patient reported outcomes · IA_BE_4: Engagement of patients through implementation of improvements in patient portal · IA_BE_15: Engagement of patients, family and caregivers in developing a plan of care · IA_BMH_2: Tobacco use · IA_EPA_1: Provide 24/7 access to MIPS-eligible clinicians or groups who have real-time access to patient’s medical record · IA_EPA_2: Use of telehealth services that expand practice access · IA_PCMH: Electronic submission of patient-centered medical home accreditation · IA_PM_16: Implementation of medication management practice improvements · IA_PSPA_28: Completion of an accredited safety or quality improvement program |
Total Per Capita Cost (TPCC) |
| FOUNDATIONAL LAYER | ||
| Population Health Measures | Promoting Interoperability | |
|
· Q479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment System’s (MIPS) Eligible Clinician Groups
· Q484: Clinician and Clinician Group Risk standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions |
· Security Risk Analysis
· Safety Assurance Factors for EHR Resilience Guide (SAFER Guide) · e-Prescribing · Query of the Prescription Drug Monitoring Program (PDMP) · Provide Patients Electronic Access to Their Health Information · Support Electronic Referral Loops by Sending Health Information AND Support Electronic Referral Loops by Receiving and Reconciling Health Information OR · Health Information Exchange (HIE) Bi-Directional Exchange OR · Enabling Exchange under the Trusted Exchange Framework and Common Agreement (TEFCA) · Immunization Registry Reporting · Syndromic Surveillance Reporting (Optional) · Electronic Case Reporting · Public Health Registry Reporting (Optional) · Clinical Data Registry Reporting (Optional) · Actions to Limit or Restrict Compatibility or Interoperability of CEHRT · ONC Direct Review |
|
Subgroup Reporting
New with MVPs, clinicians can participate via a subgroup, which is a subset of clinicians within a group (identified by a single Taxpayer Identification Number, or TIN) which contains at least two clinicians, one of whom is an individually eligible MIPS-eligible clinician. Subgroup reporting is voluntary for the 2023, 2024 and 2025 performance years. Reporting through a subgroup may be an option for clinicians in a practice with multiple specialties to get better insight into clinical areas and performance for clinicians within a practice.
MVP Registration
To report an MVP in the 2023 performance year, clinicians will need to register between April 3 and Nov. 30, 2023. At the time of registration, clinicians will need to select:
- If they plan to report as a subgroup;
- One MVP for reporting;
- One population health measure included in the MVP foundational layer; and
- Any outcomes-based administrative claims measure (if applicable) for the quality performance category.
Conclusion
These are key takeaways from the 2023 final rule; not all changes have been included in this overview. To learn more about the CY 2023 Medicare PFS Final Rule and the 2023 QPP finalized policies, download the 2023 QPP Final Rule Resources ZIP file, which includes:
- 2023 QPP Final Rule External FAQs
- 2023 QPP Final Rule MVP Table
- 2023 QPP Final Rule Overview
- 2023 QPP Final Rule Policy Comparison Tables
Questions?
Contact the Quality Payment Program at (866) 288-8292 or email [email protected].
The ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE registry at (404) 633-3777 or email [email protected].