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The 2024 Medicare PFS Proposed Rule – MIPS Updates You Need to Know

Temperatures may be reaching record highs across the nation, but that didn’t stop the Centers for Medicare and Medicaid Services (CMS) from bringing the heat with the 2024 Medicare Physician Fee Schedule proposed rule released on July 13, 2023. The good news is your DAS Health Government Incentives team has provided you with a summary of the most important updates for physician practices reporting under traditional MIPS.

Keep in mind, these changes are not yet finalized and can change.

Overall, CMS proposed a performance threshold increase from 75 to 82 points for 2024 reporting. Remember, there was no change in threshold from 2022 to 2023 reporting. This threshold would apply to both traditional MIPS reporting under the Quality Payment Program (QPP) and MIPS Value Pathway (MVP) reporting.

We will only be covering traditional MIPS updates in this article, as CMS has confirmed it will be a gradual shift to MVP reporting and is still voluntary for 2023 and 2024. In the meantime, CMS is still adding MVPs to the inventory, five of which were proposed in this rule:

  1. Focusing on Women’s Health
  2. Quality Care for the treatment of Ear, Nose and Throat disorders
  3. Prevention and Treatment of infectious disorders, including Hep C and HIV
  4. Quality Care in Mental Health and Substance Use Disorders
  5. Rehabilitative Support for Musculoskeletal Care

However, they are also taking two existing pathways, Promoting Wellness and Optimizing Chronic Disease Management, and consolidating them into a single primary care MVP. Therefore, MVP participants would have a total of 16 MVPs available for the CY 2024 performance period/2026 MIPS payment year.

Now, on to our MIPS category requirements and their updates for 2024 and beyond!

Quality

  • Addition of fourteen measures
    • One eCQM
      1. Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level)
    • Eight MIPS CQM
      1. Cardiovascular Disease (CVD) Risk Assessment Measure – Proportion of Pregnant/Postpartum Patients that Receive CVD Risk Assessment with a Standardized Instrument
      2. First Year Standardized Waitlist Ratio (FYSWR)
      3. Percentage of Prevalent Patients Waitlisted (PPPW) and Percentage of Prevalent Patients Waitlisted in Active Status (aPPPW)
      4. Preventive Care and Wellness (composite)
      5. Connection to Community Service Provider
      6. Appropriate Screening and Plan of Care for Elevated Intraocular Pressure Following Intravitreal or Periocular Steroid Therapy
      7. Acute Posterior Vitreous Detachment Appropriate Examination and Follow up
      8. Acute Posterior Vitreous Detachment and Acute Vitreous Hemorrhage Appropriate Examination and Follow up
      9. Initiation, Review, And/or Update to Suicide Safety Plan for Individuals with Suicidal Thoughts, Behavior, Or Suicide Risk
    • Four Patient Reported Outcome Measures (also MIPS CQMs)
      1. Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood
      2. Improvement or Maintenance of Functioning for Individuals with a Mental and/or substance use disorder
      3. Gains in Patient Activation Measure (PAM®) Scores at 12 Months
      4. Reduction in Suicidal Ideation or Behavior Symptoms
  • Removal of twelve measures
    1. QID 014: Age-Related Macular Degeneration (AMD): Dilated Macular Examination
    2. QID 093: Acute Otitis Externa (AOE): Systemic Antimicrobial Therapy – Avoidance of Inappropriate Use
    3. CMS 161: Adult Major Depressive Disorder (MDD): Suicide Risk Assessment
    4. QID 110: Preventive Care and Screening: Influenza Immunization
    5. QID 111: Pneumococcal Vaccination Status for Older Adults
    6. QID 138: Melanoma: Coordination of Care
    7. QID 147: Nuclear Medicine: Correlation with Existing Imaging Studies for All Patients Undergoing Bone Scintigraphy
    8. QID 283: Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
    9. QID 324: Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Testing in Asymptomatic, Low-Risk Patients
    10. QID 391: Follow-Up After Hospitalization for Mental Illness (FUH)
    11. QID 402: Tobacco Use and Help with Quitting Among Adolescents
    12. QID 436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques
  • Partial removal of three measures (used only for MVP reporting not traditional MIPS)
    1. CMS 125: Breast Cancer Screening
    2. CMS 130: Colorectal Cancer Screening
    3. CMS 69: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
  • Substantive changes to fifty-nine existing measures

Improvement Activities

  • Addition of five new activities
    1. Improving Practice Capacity for Human Immunodeficiency Virus (HIV) Prevention Services
    2. Practice-Wide Quality Improvement in MIPS Value Pathways
    3. Use of Decision Support to Improve Adherence to Cervical Cancer Screening and Management Guidelines (submitted by CDC)
    4. Behavioral/Mental Health and Substance Use Screening & Referral for Pregnant and Postpartum Women
    5. Behavioral/Mental Health and Substance Use Screening & Referral for Older Adults
  • Modification of one activity
  • Removal of three activities
    1. IA_BMH_6 Implementation of co-location PCP and MH services
    2. IA_BMH_13 Obtain or Renew an Approved Waiver for Provision of Buprenorphine as Medication-Assisted Treatment [MAT] for Opioid Use Disorder
    3. IA_ PSPA_29 Consulting Appropriate Use Criteria (AUC) Using Clinical Decision Support when Ordering Advanced Diagnostic Imaging

Promoting Interoperability

  • Increase the reporting period from a minimum of any continuous 90 days to 180 continuous days within the calendar year.
  • Updates to the clinician types approved for automatic PI reweighting to include only clinical social workers. CMS proposes not to continue the automatic reweighting for physical therapists, occupational therapists, qualified speech-language pathologists, clinical psychologists, and registered dietitians and nutrition professionals for the 2024 performance period.
  • Modification of the Prescription Drug Monitoring Program (PDMP) exclusion from less than 100 permissible prescriptions to does not electronically prescribe any schedule II opioids or schedule III or IV drugs during the reporting period.
  • Require a ‘Yes’ attestation for the SAFER Guide beginning in 2024.

Don’t forget the previously finalized 2024 PI update regarding public reporting:

  • There are two levels of active engagement which must be submitted for the Public Health and Clinical Data Exchange Objective measures:
    • Pre-production and Validation
    • Validated Data Production

Cost

  • Addition of five new episode-based cost measures beginning with the CY 2024 performance period, each with a 20-episode case minimum. The measures are:
    1. An acute inpatient medical condition measure (Psychoses and Related Conditions)
    2. Three chronic condition measures (Depression, Heart Failure, and Low Back Pain)
    3. A measure focusing on care provided in the emergency department setting (Emergency Medicine).
  • Removal of the acute inpatient medical condition measure ‘Simple Pneumonia with Hospitalization’ beginning with the CY 2024 performance period/2026 MIPS payment year.

Other Updates

  • Modification of the APM CEHRT Requirement. APMs must require the use of certified EHR technology, which means EHR technology certified under the ONC Health IT Certification Program. This removes the previous threshold of 75% of clinicians in an APM Entity (such as an ACO) must use CEHRT to be considered an Advanced APM.
  • Removal of the lump sum incentive payment for APMs starting in CY 2024/PY 2026 to a higher Medicare PFS conversion factor
  • Modification to the APM QP determination process. APM QP determinations will be made at the individual clinicians’ level and not the APM Entity level.
  • Increase in QP thresholds for Medicare payments from 50% to 75% and Medicare patients from 35% to 50.
  • Pause on implementation of the Appropriate Use Criteria (AUC) Program for reevaluation and rescind the current AUC program regulations.

CMS has made it clear we are no longer in the ‘transition period’ of the MIPS program and we are now officially moving away from the emergency response the COVID-19 pandemic required. This means a more difficult reporting program for all clinicians nationwide. We want to make sure you are prepared to report not only in 2024 but starting right now! Even if you plan to take the COVID-19 hardship for 2023, let our team help get you back into ‘MIPS shape’ so you can be ready come 1/1/2024!

Don’t hesitate to reach out to your DAS Health Government Incentives Team, we are here to help! And believe it or not, we have been told we *almost* make MIPS fun!