On July 14, the Centers for Medicare & Medicaid Services (CMS) issued its proposed policies for the Quality Payment Program (QPP) via the 2024 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM), which includes the 2024 Quality Payment Program (QPP) proposed rule.
The CMS continues its pattern of layering on refinements to the QPP and raising the standards for performance in this proposed rule. Following the end of the public health emergency (PHE) in May, the CMS has noted that it is looking forward to getting the QPP back on track with the path that was planned before the pandemic. The ACR RISE registry staff reviewed the proposed rule and highlighted key takeaways and proposed policies for the 2024 Merit-Based Incentive Payment System (MIPS) reporting period below.
Performance Category Weights
- Quality: 30% (no change from CY 2023)
- Promoting Interoperability: 25% (no change from CY 2023)
- Improvement Activities: 15% (no change from CY 2023)
- Cost: 30% (no change from CY 2023)
Performance Threshold
The CMS is proposing to increase the performance threshold from 75 to 82 points, which aligns with its goal of increasing practices’ return on their investment in MIPS participation by providing the opportunity to achieve a higher positive payment adjustment. This increase would apply to Traditional MIPS, MIPS Value Pathways (MVPs) and the Alternative Payment Model (APM) Performance Pathway (APP).
Quality Performance Category
The CMS proposes to:
- Offer 200 quality measures for the 2024 performance period; all currently available rheumatology-specific QPP measures are included in the proposal.
- Note that the CMS is proposing to:
- Remove QPP111: Pneumococcal Vaccination Status for Older Adults, because it is duplicative to measure Q493: Adult Immunization Status. QPP111 is being replaced by Q493: Adult Immunization Measure in all applicable MVPs, including the Advancing Rheumatology Patient Care MVP.
- Partially remove QPP128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan from the MIPS quality measure inventory. This measure is commonly reported via Traditional MIPS through the RISE Registry. It is proposed for removal for Traditional MIPS but retained for MVP use only; however, it is not part of the Advancing Rheumatology Patient Care MVP.
- Keep the previously finalized data completeness threshold the same at 75% for the 2024 and 2025 performance periods for electronic clinical quality measures (eCQMs), MIPS CQMs, Medicare Part B claims measures and qualified clinical data registry (QCDR) measures.
- Note that for the 2023 performance period, the data completeness threshold was 70%.
- Increase the data completeness threshold for subsequent performance periods for eCQMs, MIPS CQMs, Medicare Part B claims measures and QCDR measures:
- 75% for the 2026 performance period
- 80% for the 2027 performance period
- Modify the criteria used to assess ICD-10 coding updates:
- Eliminate the automatic 10% threshold of coding changes that triggers measure suppression or truncation;
- Assess the impact of coding changes on a case-by-case basis; and
- Assess each collection type separately of a given measure in order to determine the appropriate action to take for a measure affected by an ICD10 coding update.
- Note that the CMS is proposing to:
Promoting Interoperability Performance Category
The CMS proposes to:
- Update the certified electronic health record technology (CEHRT) definition to align with the Office of the National Coordinator for Health IT (ONC)’s regulations.
- Continue automatic reweighting for clinical social workers in the 2024 performance period.
- Discontinue automatic reweighting, beginning with the 2024 performance period, for the following clinician types: physical therapists, occupational therapists, qualified speech-language pathologists, clinical psychologists and registered dietitians or nutrition professionals.
- Increase the performance period to a minimum of 180 continuous days within the calendar year.
- Modify the Query of Prescription Drug Monitoring Program (PDMP) Measure Exclusion to the following: “Does not electronically prescribe any Schedule II opioids or Schedule III or IV drugs during the performance period.”
- Require a “yes” response for the SAFER Guide measure beginning with the CY 2024 performance period.
Improvement Activities Performance Category
The CMS is proposing to update the improvement activities inventory by:
- Adding five new improvement activities;
- Note: One new proposed improvement activity is “Practice-Wide Quality Improvement in MIPS Value Pathways,” which is proposed to be added to the Advancing Rheumatology Patient Care MVP.
- Modifying one existing improvement activity; and
- Removing three existing improvement activities.
- Note: IA_ PSPA_29 is proposed for removal and is commonly reported through the RISE Registry.
Cost Performance Category
The CMS proposes to:
- Calculate improvement scoring for the cost performance category at the category level without using statistical significance, beginning with the CY 2023 performance period/2025 MIPS payment year;
- Have the maximum cost improvement score of 1 percentage point out of 100 percentage points to be available beginning with the CY 2023 performance period/2025 MIPS payment year; and
- Have the maximum cost improvement score available for the CY 2022 performance period/2024 MIPS payment year to be 0 percentage points.
MVPs
The CMS proposes:
- Five new MVPs to be available with the 2024 performance year, along with revisions to all previously finalized MVPs. The five newly proposed MVPs are:
- Focusing on Women’s Health
- Quality Care for the Treatment of Ear, Nose, and Throat Disorders
- Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
- Quality Care in Mental Health and Substance Use Disorders
- Rehabilitative Support for Musculoskeletal Care.
- A policy to clarify that it will not calculate a facility-based score at the subgroup level.
- To add §414.1365(e)(4)(i) to clarify that, beginning with the 2023 performance period/2025 MIPS payment year, subgroups would receive their affiliated group’s complex patient bonus, if available.
- Subgroups would only receive reweighting based on any reweighting applied to its affiliated group.
The Advancing Rheumatology Patient Care MVP
The CMS is proposing to modify the previously finalized Advancing Rheumatology Patient Care MVP to:
- Add four quality measures:
- Q487: Screening for Social Drivers of Health
- Q493: Adult Immunization Status
- TBD: Gains in Patient Activation Measure (PAM) Scores at 12 Months
- UREQA10: Ankylosing Spondylitis: Controlled Disease Or Improved Disease Function
- Remove Q111: Pneumococcal Vaccination Status for Older Adults in favor of adding Q493: Adult Immunization Status
- Add four improvement activities:
- IA_BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings
- IA_BE_24: Financial Navigation Program
- IA_BE_25: Drug Cost Transparency
- IA_MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
Targeted Review
The CMS proposes:
- To open the targeted review submission period upon release of MIPS final scores and to keep it open for 30 days after MIPS payment adjustments are released. This would still maintain an approximately 60-day period for requesting a targeted review: about 30 days before and 30 days after payment adjustments are released.
What Does this Mean for Your Practice?
Whether and how much your practice will be impacted depends on several factors. Consider:
- Does your practice plan to report through Traditional MIPS, the Advancing Rheumatology Patient Care MVP or both?
- Will you report as a group, subgroup or individual?
- What is your practice’s eligibility?
- Does your practice have additional reporting factors, such as special status or hardship exceptions?
Practices are encouraged to contact RISE staff at [email protected] with any questions regarding how they will be affected by these proposed policies.
The ACR will comment on the proposed rule on behalf of the specialty. Members may comment to the CMS directly by 5:00 p.m. EDT on Sept. 11, 2023. The proposed changes are not finalized until the the CMS announces the final rule, which is expected around November 2023. At that time, the ACR will review and evaluate the final rule and provide more information.
Additional Resources
These are key takeaways from the proposed rule; this is not a comprehensive list of all proposed changes. Additional information is available here:
- 2024 QPP Proposed Rule
- 2024 QPP Proposed Rule Fact Sheet & Policy Comparison Table
- 2024 Proposed and Modified MVPs Guide
Questions?
Contact the Quality Payment Program at 1-866-288-8292 or [email protected].
The ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE team at 404-633-3777 or [email protected].
