Do You Know QPP MIPS Reporting 2023 Has More Options but Is Very Challenging?

QPP MIPS 2023 reporting comes with so many options and so many changes from the MIPS program before. There are also so many challenges that the physicians need to face.

MIPS 2023 Final Rule Has Been Released 

With the release of MIPS 2023, the Centers for Medicare and Medicaid Services (CMS) has finalized most of the proposed changes for the QPP MIPS Reporting 2023.

We are seeing that while the payment threshold is holding at 75 points, it could be difficult to achieve that threshold score with the change in the MIPS program for 2023.

Challenges in MIPS 2023 

• Quality Measures that had the highest score in history will be topped out and removed from the program. What is meant by this? It means it will be harder to find the Quality measures where the physicians will be able to achieve 20 points. 
• The Cost performance category is not monitored by CMS during the performance year. Scores are assigned to providers based on how they performed in the past in comparison to other providers. Scores will cluster around 15/30. Why does this matter? Very likely, you won’t get 15 out of a possible 100 points for your MIPS 2023 score if any of the expense category measures apply to your reporting.
• MIPS Value Pathway (MVPS) scoring is very challenging. Each MVP contains at least one Cost measure. Additionally, there is at least one population measure applied to the score, and your team has no insight into what that score will be. What does it mean? You’ll gain less insight into your final score if you report on MVP.
• Due to the difficulties associated with the many reporting alternatives, “simple” reporting mechanisms, such as eCQMs from a certified electronic health record system (CEHRT), may cause providers to receive a fine. Why does this matter? A provider or group must receive flawless scores for Promoting Interoperability (PI) and Improvement Activities (IA) to receive a score of 20/30 in the Quality category, or an average of seven points for each reported measure. Many providers will have to do this to locate specialty measurements or work on performance improvement in their measures to reach the required level and avoid a fine. An EHR or CEHRT reporting tool frequently does not provide this chance to assess and enhance.
• There are so many options for reporting. Each of the options will most likely give different results. What is meant by this? We suggest beginning to collect your data early in the year and reviewing it mid-year to determine the optimal path to reporting.

In 2023, MVP offers an opportunity to focus on the specialties and narrow the quality reporting requirement to only four measures. Also, when an MVP is submitted, only the cost measures that are relevant to that MVP is considered when applying cost measures.

Making use of our registry is a terrific way to examine your data and choose the best reporting approach. It is possible to calculate scores for eCQMs, CQMs, MVPs, APMs, people, and organizations.

How Does the Working of MVP Occur, and What are the Challenges?

In contrast to standard QPP MIPS, MVPs are a subset of previously established metrics and activities that have been organized for a particular disease or specialty. The objective, according to CMS, is to switch from soloed reporting of measures and activities to concentrated sets of measurements and activities that are more significant to a clinician’s practice, specialty, or public health concern.

Hence, the alignment and connection of measures and activities across the performance categories of quality, cost, and improvement activities will be accomplished via the MVP architecture. The population health claim-based measurements and the Fostering Interoperability performance category are the basic components of the MVPs.

Limited, connected, complementary measures and activities that are defined for that specific pathway will make up the measures and activities that will be reported under MVPs. As a result, businesses utilizing the MVP paradigm won’t be able to report on particular metrics of their choosing.

What are The Participation Options?

For the performance year 2023-2025 below are the participants:

• A subgroup 
• An Individual Clinician 
• A single or multispecialty group 
• An alternative payment model (APM) entity 

During each reporting period, an MVP participant is limited to taking part in a single MVP. However, a single physician can take part in more than one MVP by reporting as a member of two subgroups—one for one pathway and the other for a different pathway. Multispecialty groups must organize into subgroups by the performance year 2026 to participate in MVP.

One or more MIPS-eligible clinicians working for a group practice are considered a subgroup. For a single- or multispecialty group, CMS has suggested using the Provider Enrollment, Chain, and Ownership System (PECOS) to determine the specialty type.

During each performance year, participants must register their reporting status between April 1 and November 30. Upon registration, a participant will decide between the following options:

• The MVP they want to mention
•  One indicator of population health included in the MVP
• If provided inside the MVP, any outcomes-based administrative claims metric that the participant desires to be rated on

The following will also be required of each subgroup:

• Determine the MVP, including the population health measure and any administrative measures that the subgroup plans to be graded on, for which it will submit its report.
• Use the National Provider Identifier (NPI) and Taxpayer Identification Number (TIN) to locate the clinicians in the subgroup (NPI)
• For the sake of public reporting, give the subgroup a name in everyday language.

When the registration period closes on November 30, a participant will not be allowed to submit or modify the MVP they have chosen, nor will they be permitted to report on an MVP for which they did not register.