November 7, 2023

MIPS 2024 Final Rule: Impact for CEDR and Participants

CMS published the MIPS 2024 Final Rule on November 1, 2023. The following is ACEP’s impact analysis.

After 5 years, the special COVID hardship waiver has ended. In 2024, MIPS will be fully in force for all eligible clinicians, across all specialties.
The “neutral payment” threshold to avoid a penalty remains at 75 points (same as 2022 & 2023). CMS had originally proposed 82, so this was a surprise.
Data completeness requirement has increased to 75% (up from 70% in 2021 to 2023). This is unlikely to have an impact on CEDR, but may for other alternatives (QRs).
Cost scoring is being fully implemented with new episode-based cost measures, accounting for 30% of the final MIPS score. Clinicians will have no prospective insight into this process, so it becomes a major risk.
MIPS Value Pathway (MVP) enters its second year and remains optional for the foreseeable future, although CMS has indicated it plans for MVP to replace traditional MIPS within 5–6 years.
ACEP’S MVP “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine” has been updated.
Beginning in 2025, healthcare IT vendors will need to become a Qualified Registry (QR) Qualified Clinical Data Registry (QCDR), like CEDR in order to report MIPS.

Having sat out for years, many clinicians and groups are unprepared for MIPS in 2024.
CMS projects that only around 21.6% of providers will receive a penalty with the performance threshold remaining at 75 points. 78.37% of clinicians are expected to receive a neutral or positive payment.
CMS projects the median positive payment adjustment will be +1.74% and the median negative payment adjustment will be -1.24 percent.
For larger practices (>15 clinicians) quality measures meeting data completeness and case minimum will be scored on a 1 to 10-point scale, instead of a 3 to 10-point scale. This 3-point floor remains for smaller practices.
CMS has finalized removal of 11 MIPS quality measures, modified 59 existing measures, and added 13 new quality measures. One public domain measure available to emergency medicine (QPP-93 Avoidance of systemic antibiotics for otitis externa) was removed.

CEDR is approved as QCDR for 2024 for both Emergency Medicine and Hospital & Observation Medicine Registry (HOMR). HOMR will begin providing services on January 1, 2024.
Out of 30 proposed CEDR QCDR quality measures, 23 were approved (including 4 for HOMR). The 7 rejected measures will be appealed for reconsideration, as has been the case in prior years for some of these same measures. Irrespective of the appeal, there should be no significant impact on CEDR participants, since only 6 measures are required for MIPS reporting. Public (QPP) measures can also be used to supplement CEDR’s QCDR measures, particularly for HOMR (for a minimum total of 9).
CMS will allow cooperation (dual reporting) between a QR & QCDR. This means billing companies that promote their manually coded quality measures via a QR can partner with ACEP to augment their MIPS offering by having CEDR also submit its QCDR measures on behalf of the physician group. ACEP is exploring this option, which may offer a smooth transition for these groups as they build out their clinical data feed &/or offer new life to QRs likely to struggle to avoid MIPS penalties without the benefit of CEDR’s QCDR measures.

Register today for our upcoming webinar on this topic.

“Are You Ready for MIPS 2024?”

The American College of Emergency Physicians (ACEP) will hosting a live webinar on Wednesday, November 15, 2023, at 2 pm CST.

Presenters include:

Jeffrey Davis, Health Policy Director, McDermott+Consulting

Pawan Goyal, MD, MHA, MS, PMP, FAMIA, FAHIMA, FHIMSS,

Senior Vice President, Quality

Bill Malcom, MBA, MS, PMP, Program Director, Data, and Quality

In this webinar we will cover following topics:

Register using this link: https://webapps.acep.org/meetingsv1/Registration.aspx?mcode=AVS-1115

Pawan Goyal MD, MHA, MS, PMP, FAMIA, FAHIMA, FHIMSS

Senior Vice President, Quality

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