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What changes in MIPS framework should Medical Coders and Medical Billers expect in 2023?

MPFS rule brings notable MIPS changes for 2023. CMS updates on MIPS categories post-COVID-19-PHE.

MIPS is the default QPP pathway for most providers. MIPS has 4 weighted performance categories.

  • Quality
  • Cost
  • Improvement Activities
  • Promoting Interoperability

Each MIPS performance category contributes a specified weight to the MIPS final score

MIPS score affects payment adjustments.

  • Scores below the threshold face a -9% payment penalty.
  • Scores above the threshold earn a +9% payment incentive.
  • No MIPS reporting = -9% penalty.
  • Threshold score = 0% payment adjustment.

MIPS reporting requires advanced preparation. These coming months are very crucial if you want to participate in MIPS and get things started well in time. The article covers pre- and post-PHE MIPS changes for 2023.

How was MIPS impacted by COVID-19 PHE?

During CMS, we approved COVID-19 PHE exclusion for affected clinicians. COVID-19 PHE brought neutral adjustments and delayed penalties/incentives for 2021-2022.

MIPS resumes in 2023 with up to 9% penalties and bonuses for eligible clinicians. 2023 performance determines 2025 Medicare payments.

Changes made for Merit-Based Incentive Payment System (MIPS) in 2023:

CMS proposes 75 point threshold based on 2019 data, subjecting 1/3 to 2023 penalties. 75 point threshold is higher than 60 points in 2021. Exceptional Performance is set to be retired.

Following are the CMS proposed category-based changes for 2023:

Quality:

CMS finalized 198 quality measures for 2023, which reflect the following:

  1. CMS proposes 75% data completeness for 2024.
  2. CMS proposes modifications to the quality measure set. Larger practices: 10-point quality scoring, 75% data completeness. Smaller practices: 1-3 point scoring for measures without benchmark or <20 cases.
  3. CMS prioritizes health equity and adds disparity questions to CAHPS.
  4. CMS proposes scoring admin claims measures on current year data.
  5. CMS proposes complex patient bonus updates for health equity.

Cost:

  1. CMS proposes methodological updates to the Medicare Spending Per Beneficiary measure.
  2. CMS proposes a 1% credit for cost improvement.
  3. No other significant changes were proposed.

Improvement Activities:

No major changes to the MIPS Improvement Activities (IA) category, just IA inventory updates. CMS intends to retire and modify a handful of activities to avoid duplication.

  1. Proposed new IAs: Language Access Plan (high) and COVID-19 Vaccination for Staff (medium).
  2. Proposed: 5 changes to existing IAs, including QCDR use for practice assessment.
  3. Proposed IA removals: QCDR population health reports, Rx monitoring.

Promoting Interoperability:

CMS proposes several measure-specific changes for this category, including:

  1. PDMP query measure is now mandatory with opioid drug inclusion.
  2. HIE Objective offers a TEFCA reporting alternative (yes/no).
  3. Public Health and Clinical Data Exchange Objective Exchange Objective to 25 points.
  4. Patients' Electronic Access measure was reduced to 10 points.

CMS mandates active engagement on each measure with reported engagement validation. Proposed: Discontinue PI category reweighting for NPs, PAs, CRNAs, and CNSs.

Performance Year 2023 MIPS Value Pathways

From 2023, CMS will offer 7 MVPs for voluntary MIPS participation. MVPs include tailored quality, improvement activities, and cost measures.

Rheumatology:

Advancing Rheumatology Patient Care

Stroke Care and Prevention:

Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes

Heart Disease:

Advancing Care for Heart Disease

Chronic Disease Management:

Optimizing Chronic Disease Management

Emergency Medicine:

Adopting Best Practices and Promoting Patient Safety with Emergency Medicine

Lower Extremity Joint Repair:

Improving Care for Lower Extremity Joint Repair

Anesthesia:

Support of Positive Experiences with Anesthesia

For the CY 2023 performance period, CMS will add 5 new MVPs to the previously announced 7 MVPs in the program.

Final Word:

MIPS promotes quality healthcare for patients. MIPS participation can improve healthcare standards and earn incentives.

Prepare for CY2023 MIPS now. Participate to avoid penalties during recent PHE challenges.

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