MIPS Ramps Up in 2024: Are you Ready?

MIPS Ramps Up in 2024: Are you Ready?

Executive Summary

• 2024 will (likely) be the first year in the last 5 when MIPS will be fully in force.
• Having sat out for years, many clinicians are grossly unprepared for MIPS.
• You need at least 3 months lead time before January first to be prepared for 2024.
• The threshold to avoid a penalty will (likely) increase by 7 points to 82.
• CMS estimates 54% of clinicians will receive penalties in 2024.
• No matter what solution you use to report MIPS, significant additional effort will be necessary to avoid a penalty in 2024.
• For all of the reasons above, 2024 will have an unprecedented MIPS bonus pool available for those who are well prepared and do the quality work.
• If you do not currently have a functioning MIPS solution, you are already behind.

On July 13, 2023, the Centers for Medicare and Medicaid Services (CMS) released a Medicare annual proposed payment rule for calendar year (CY) 2024 that impacts payments for physicians and other health care practitioners. The proposed rule combines policies for the Medicare physician fee schedule (PFS) with the Merit-based Incentive Payment System (MIPS)—the quality performance program established under the Medicare Access and CHIP Reauthorization Act (MACRA).

CMS introduced policies that will impact the seventh performance year (2024) of the Quality Payment Program (QPP), which includes the MIPS and Advanced Alternative Payment Models (APMs). MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Performance on these four weighted categories rolls up into an overall score which translates to an upward, downward, or neutral Medicare payment adjustment. This adjustment is received by providers two years after the performance period (for example, performance in 2024 will impact Medicare payments in 2026).

Created by ACEP staff, this will summarize the relevant policies of the MIPS 2024 proposed rule and their impact on emergency physicians:

• Extend 2023 Reporting Exemptions due to COVID-19: CMS is granting hardship exemptions on a case-by-case basis due to COVID-19. It is therefore possible for a clinician or group to request to be exempted from all four performance categories in 2023. If clinicians are approved for a hardship exception application for all four MIPS performance categories, they will be held harmless from a payment adjustment in 2025—meaning that they will not be eligible for a bonus or potentially face a penalty based on their MIPS performance in 2023. There is no indication that this will be extended into 2024.
  
  
• Offer MVPs: The 2024 performance year is the second year in which a new reporting option called MIPS Value Pathways (MVPs) is available. MVPs represent an approach that will allow clinicians to report on a uniform set of measures on a particular episode or condition to get MIPS credit. ACEP developed an emergency medicine-focused MVP that CMS included in the first batch of MVPs that began this year.
  
  
• Increase Performance Threshold: CMS proposes to increase the threshold that clinicians need to achieve to avoid a penalty to 82 points in 2024—7 points higher than the threshold in 2023. CMS under law must set the performance threshold at the mean or median of a prior performance year, and they decided to pick the 2019 performance period when setting the 2024 performance threshold. There is no exceptional bonus threshold starting in the 2023 performance period.
  
  
• Increase the data completeness criteria threshold from 70 percent to 75 percent for the CY 2024 and 2025 performance periods.

Additional MIPS 2024 Proposed Policies

• Increase the inventory of quality measures from 198 to 200 through the addition of 14 and the removal of 12 MIPS quality measures;
• Add 5 new episode-based cost measures (including the emergency medicine cost measure);
• Add 5 new improvement activities, modify 1 existing improvement activities, and remove 3 existing improvement activities for a total of 106 in the MIPS inventory;
• Increase the performance period to a minimum of 180 continuous days within the calendar year;
• Clarify that if a facility-based clinician reports through an MVP, CMS will take the higher of the MVP score and the score the clinician the receives through facility-based measurement;
• Eliminate the health IT vendor category of third-party intermediaries, beginning with the CY 2025 performance period, to remove gaps in third party intermediary requirements and improve data integrity.

ACEP is working hard to make sure that your interests as emergency physicians and the patients you serve are represented in our comments. In particular, your comments on the first four bullet points are appreciated for ACEP’s response.

Please contribute your comments or reply to psharma@acep.org prior to the September 1, 2023, deadline.