As with previous PFS final rules, clinicians were expecting custom modifications to the rule. Back in the day, by the PFS proposed rule, CMS had forecasted the coming changes in the final rule. So, the wait is finally over, as CMS released the final rule on November 2, 2023. The rule for PY 2024 specially addresses the policy changes related to the following:
- Traditional MIPS
- Alternative Payment Models (APMs)
- Accountable Care Organizations (ACOs)
- MIPS Value Pathways (MVPs)
We have divided this policy change summary into three main parts for a broader perspective. So, we will be posting three blogs in series to help you better getting familiar with the new policy. This marks the blog ‘Part A’ of MIPS 2024 policy changes, covering the policies concerning:
- MIPS Performance Threshold
- MVPs Expansion
- Targeted Review Timeline
Now, let’s unroll and see what’s in the PFS final rule for CY 2024 reporting!
From MIPS 2017 to 2022, the federal state has gradually modified the performance threshold for participants. By doing so, they practiced setting higher care standards for providers to beat them. For PY 2022 reporting, clinicians required 75 points in MIPS final score to stay safe. It means the fate of clinicians depends on this threshold. For PY 2022 reporting, they will get penalties or incentives up to 9 percent accordingly in the payment adjustment period. So, the proposed rule for MIPS 2024 has favored the idea of increasing the performance threshold to 85 points. Anyhow, the final rule declares the confirmed decision from CMS’s side, i.e.,
To fulfill the performance criteria in MIPS 2024 reporting, providers must score at least 75 points.
Not only is the performance threshold unchanged, but the payment adjustment ratio is still the same. Therefore, the following will be the distribution of the 2024 final score and the 2026 payment adjustments:
- For scoring 0.0 to 18.75 MIPS final points, the payment adjustment will be -9%.
- For 18.75 to 74.99 MIPS final points, the payment adjustments will be up to -9%.
- If participants get 75 points in the MIPS final score, the payment adjustments will be zero. They will be in a neutral position.
- For a 75.01 final score in 2024, the 2026 payment adjustments will be greater than zero on a linear sliding scale. Here, again, up to 9% is the limit for positive payment adjustments for scoring up to 100 points.
(Note: To keep the budget neutral, we multiply the sliding scale with the scaling factor.)
As we know, MVPs are the new reporting option available for MIPS participants. Continuing these options in MIPS 2024, CMS has given expansion to MVPs. For CY 2024, there are 16 MVPs available, with 5 new additions:
- Focusing on women’s well-being
- Quality Treatment for Ear, Nose, and Throat Disorders
- Infectious disease prevention and treatment, including hepatitis C and HIV
- Mental Health and Substance Use Disorders Care of High Quality
- Musculoskeletal Rehabilitation Assistance
Likewise, previous MVPs have also been modified. For instance, we have one single MVP for Promoting Wellness and one for Optimizing Chronic Disease Management. CMS has combined two of them under a modified MVP called ‘Value in Primary Care MVP’.
Here is the list of modified MVPs in the MIPS 2024 final rule:
- Value in Primary Care
- Advancing Cancer Care
- Optimal Care for Kidney Health
- Advancing Care for Heart Disease
- Advancing Rheumatology Patient Care
- Improving Care for Lower Extremity Joint Repair
- Supportive Care for Neurodegenerative Conditions
- Patient Safety and Care of Positive Experiences with Anesthesia
- Optimal Care for Patients with Episodic Neurological Conditions
- Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
- Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
There is no change finalized in the MIPS targeted review timeline. Just after releasing the MIPS final scores, a targeted review submission period will start. There will be a 60-day period for requesting a target review. This period will end after 30 days of releasing MIPS payment adjustments. Also, the clinicians are bound to submit the requested information to CMS within 15 days of receiving such a request.
It’s already been a long time for MIPS-eligible clinicians who are wrapping up their MIPS 2023 reporting. Now is the time for them to show maximum attention. Get ready for MIPS 2024 reporting. They must enter PY 2024 with a compelling strategy without compromising their 2023 reporting. And again in 2024, QPP MIPS is ready to assist with their MIPS consulting services. As an MIPS-qualified registry, we know the intricacies of MIPS very clearly.
That’s why we can tell you:
- How do I stay safe and hit the maximum MIPS score for incentives?
- What are your improvement areas for striking MIPS reporting?
- What quality measures best cover your specialty services?
- Which improvement activities can work for enhancing your practice’s MIPS score?
- How can we get rid of the threat of MIPS penalties?