COVID-19 had, however, caused considerable distortions, compelling CMS to give more flexibility to clinicians. Anyhow, the world has now overcome the conditions, while financial problems are still unresolved. So, CMS is also aiming to get back on track with its new policy and modification of the MIPS rule.
We are rolling down to the next part of our MIPS 2024 final rule policies. In this part, we will discover the modifications in each of the four MIPS performance categories. All these categories focus on different but interconnected parts of care delivery to patients. Anyhow, they collectively contribute to implementing the value-based care model in healthcare. Advancing care and improving patient outcomes are the initial motives of the MIPS reporting framework.
Now, let’s see what changes in performance categories the PFS final rule for CY 2024 has brought.
The contribution of the MIPS quality category to final scoring is unaltered. However, the policy for MIPS 2024 has two major modifications in its quality category:
- Data completeness criteria
- Quality measures inventory
Long before passing the final rule, the new quality data completeness criteria had been set. In the previous policy, participants must report data for 70% of Medicare Part B-eligible encounters. However, CMS has rethought the data sufficiency for evaluating the performance quality. Therefore, it’s pre-decided to increase the criteria to 75% for PY 2024 and 2025 onwards. This upgraded criterion applies to eCQMs, MIPS CQMs, Part B claims measures, and QCDR measures. In the MIPS 2024 final rule, CMS has finalized this 75% minimum reporting criteria for PY 2026 reporting as well.
While the inventory has undergone modifications, the total measures on the list are still 198.
The table given below represents the modifications finalized for MIPS 2024:
|New Quality Measures||11|
|Removed Quality Measures||11|
|Substantively Changed Quality Measures||59|
|Partially Removed Quality Measures||3|
All three partially removed quality measures are still available for MVP reporting in MIPS 2024. However, ACOs using the CMS Web Interface Collection type can opt for measures 112 and 113.
Apart from this, CMS also decided the fate of two radiology measures with a one-year delay. In other words, it is a final decision to remove or add two radiology measures:
- A new eCQM measure is to be added for FY 2025:
Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level)
- Measures to be removed for FY 2025:
#436 Radiation Consideration for Adult CT: Utilization of Dose-Lowering Techniques
[Note: No worries; it is safe if you are planning to report measure #436 in MIPS 2024. This measure is still part of MIPS for FY 2024.]
The MIPS framework is more about improving care standards; it also means delivering ‘cost-efficient care’. The cost category evaluates the methods and costs applied to healthcare. The MIPS 2024 final rule modifies cost score calculation methods and cost measures.
Both the quality and cost categories have equal proportions in the MIPS final score, i.e., 30% each. MIPS 2024 modifies the policies for the quality category, as we have discussed above. Owing to these changes, we have a new scoring calculation method. Starting with the performance period in 2023, CMS implements the following policy for scoring:
- Instead of using measure level for scoring, the ‘category level’ is a new criterion for calculation.
- Without using statistical significance, scoring will be based on mathematical and operational feasibility.
In FY 2024, we have 29 cost measures available for score determination. While adding five episode-based measures to the 2024 PFS rule, CMS has exempted one measure.
Here, the table represents the cost measures being added or removed:
|New Episode-based Cost Measures||Measures to be Removed|
|Depression (a chronic condition)||Acute Inpatient Medical Condition Measure; Simple Pneumonia with Hospitalization|
|Low back pain (chronic condition)|
|Emergency medicine (care provided within any emergency department setting)|
|Heart failure (chronic condition)|
|Psychoses and related conditions (an acute inpatient medical condition)|
This category of MIPS reporting framework focuses on initiatives for enhancing the patient experience. So, to practice a patient-centered approach in care delivery, the MIPS 2024 IA inventory has been modified. With a total of 106 IAs, clinicians will now have two more activities in the finalized policy. In the previous policy, the inventory had 104 improvement activities in total.
The following table represents the summary of improvement activity updates in MIPS 2024:
|New Improvement Activities||5|
|Removed Improvement Activities||3|
|Modified Improvement Activities||1|
Note: Among the 5 newly added activities, we have one MVP-specific activity. CMS has titled it “Practice-Wide Quality Improvement in MVPs.”
The MIPS 2024 final rule includes considerable changes for the Promoting Interoperability category. Some of the major changes in PI category are given below:
- Starting in CY 2024, the MIPS performance period length will be increased. Now, it will consist of a minimum of 180 continuous days during the calendar year.
- Likewise, CMS has finalized the clinician types for discontinuing or continuing automatic reweighting in FY 2024.
|Automatic Reweighting for Clinician Types|
|Physical therapists||Clinical social workers|
|Occupational therapists||Clinicians in a small practice|
|Registered dietitians or nutrition professionals||Non-patient-facing clinicians and groups|
|Qualified speech-language pathologists||Hospital-based clinicians and groups|
|Clinical psychologists||ASC-based clinicians and groups|
- The definition of CEHRT has been modified to meet ONC standards. As a result, CMS has substituted the latest “ONC health IT certification criteria” for the prior “2015 Edition health IT certification criteria.”
Thus, MIPS 2024 policy showcases the sheer attention of CMS to move back to its original track. Therefore, it has closely overlooked the intricacies of MIPS reporting. And finalize modifications in the four performance categories to facilitate reporting. Although there is no such change in the performance threshold for MIPS, the performance evaluation process has taken center stage in policy. With these modifications, CMS will be able to access clinicians’ performance across a broader spectrum.
Here, QPP MIPS comes into the scene with flying colors with its MIPS consulting services. As a MIPS qualified registry, our guidance will be based on our reporting experience. So, our MIPS consulting services can be a guiding light for your success in reporting.