After discussing the MIPS 2024 final rule policy, we are now presenting ‘Part C’ of our blog series. The first two parts explain the modifications linked to traditional MIPS reporting 2024 final rule. Likewise, we also discussed updates concerned with MVPs reporting. Now, we are left with modifications related to MIPS 2024 participation via APP reporting. For APP participants, CMS has proposed some new updates to the PFS proposed rule. Likewise, some policies have already been finalized with the QPP MIPS 2023 policy.
For those who are new to MIPS reporting 2024 final rule, we will be giving an introduction to the APM performance pathway. And how MIPS 2024 reporting and APP are linked to one another.
Now let’s get started with MIPS 2024 final rule policy updates with a short introduction to the APP!
APM Performance Pathway for MIPS 2024 Final Rule Reporting
Under the Quality Payment Program, we have two reporting frameworks: the MIPS and the APMs. Like MIPS 2024 final rule, APMs provide a distinct payment model for incentivizing clinicians for their fine performance. The APM participants strive to deliver high-quality and cost-efficient care as a part of the broader QPP.
However, for the clinicians following the APMs, QPP has a reporting pathway within MIPS 2024 final rule. We call it the Advance APM Performance Pathway (APP). It means APM participants can take part in MIPS 2024 final rule using this passage. However, there is one condition for immediate exemption from MIPS: APM participants reporting via MIPS must not get a QP status during the performance year.
MIPS Final Rule 2024 Rules Applied to the Advanced APM Performance Pathway (APP)
Final Call for Sunset of the CMS Web Interface
CMS has already terminated the CMS Web Interface as being used as a collection type by traditional MIPS final rule reporting. However, CMS has allowed Medicare ACOs to keep using this collection type until CY 2024. So, in the MIPS 2024 final rule policy, CMS has again mentioned that the termination is final for ACOs too. In other words, the MIPS 2024 final rule policy declares that the timeline for the sunset of the web interface is still the same. In FY 2024, Medicare ACOs can conveniently report using this collection type under APP only. However, with the start of PY 2025, they will only have three choices, given as follows:
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- eCQMs
- MIPS CQMs
- Medicare CQMs (new)
Medicare CQMs: Creation of a New Collection Type for ACOs
eCQMs and MIPS CQMs are the collection types already established for ACOs reporting via APP. However, CMS has observed several data collection and patient matching issues over time. And in the MIPS 2024 final rule policy, CMS has finally made amendments to address these issues. Therefore, CMS has forwarded a new collection type, Medicare CQMs, to resolve the issues.
Medicare CQMs collective type gives one most prominent benefits to MSSP ACOs. Now, there is no need to report data on all-payer/all-patient populations. Instead, they will be reporting data only on ACO’s Medicare beneficiaries. CMS will send Medicare CQM-eligible patient lists to ACOs quarterly. These lists will include encounters on specific dates and will be updated regularly. Moreover, the list will provide in-depth, beneficiary-level information to ACOs.
Here is the CQM-eligible patient list delivery schedule mentioned in the MIPS final rule 2024 policy:
| CQM-eligible Patient Lists Delivery Schedule | |||
| Quarter | Dates of service | Expected Delivery in (Month) | |
| From | to | ||
| 1st Quarter | January 1 | March 31 | May |
| 2nd Quarter | January 1 | June 30 | August |
| 3rd Quarter | January 1 | September 30 | November |
| 4th Quarter | January 1 | December 31 | February (in the year following the performance year) |
| Note: In the fourth quarter, ACOs can cross-check the list. In this way, they will ensure they’ve considered all Medicare CQM-eligible beneficiaries. |
Although CMS will provide CQM-eligible patient lists, it’s only for data aggregation purposes. It’s not a replacement for the need for a thorough evaluation of measure criteria. Therefore, ACO may use multiple sources for verifying patient data against Medicare CQM Specifications. These resources can be either EHRs, registries, etc.
Remember that Medicare CQMs are not a permanent collection type for ACOs. CMS confirms the eventual sunsetting of this new collection type. This decision favors potential alignment with FHIR API adoption, based on industry readiness and CMS requirements.
Right now, the changes in MIPS final rule 2024 aim to provide the following benefits to MSSP ACOs:
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- Lower the reporting burden on ACOs.
- Assist them in capturing all eligible beneficiaries.
- Allow them to pre-prepare submission data.
- Assist them in identifying eligible populations for each measure.
Data Completeness Requirements Applicable to Medicare CQMs
From the PY 2024 to 2026 onward, the criterion is the same for the Medicare CQMs, i.e., 75%.
Requirement for CEHRT
For now, CMS is pushing back the CEHRT threshold changes for MSSP ACOs by a year. Thereby, it will be effective in the 2025 performance year. Subsequently, all MIPS-eligible clinicians, qualifying APM participants (QPs), and partial QPs participating in an ACO, irrespective of track, must adhere to CEHRT.
Mentioned below are the reporting requirements for ACOs:
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- Reporting Promoting Interoperability (PI) category measures is necessary for the following:
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- All MIPS-eligible clinicians, QPs, or partial QPs participating in the ACO as an individual, group, or virtual group; or
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- The AMP entity in ACO
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- All MIPS-eligible clinicians, QPs, or partial QPs participating in the ACO as an individual, group, or virtual group; or
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- Earn the PI category score for reporting at a certain participation level (individual, group, virtual group, or APM entity level).
Conclusion
In conclusion, all we have to say is that the MIPS 2024 PFS Final Rule isn’t just a rule. It’s a roadmap to healthcare excellence. It is shaking up healthcare reporting for Medicare ACOs by updating APP requirements. Therefore, all providers and medical practices must understand these changes. They must adapt to new policy changes and revise their reporting strategies for MIPS 2024 final rule reporting.
Whoever wants to ensure compliance and optimize their performance, QPP MIPS stands as a valuable ally for them in this journey. We provide MIPS consulting services to providers with different specialties. Being an MIPS-qualified registry, our experience makes us perfect for helping you make compelling strategies.
