What changes in MIPS framework should Medical Coders and Medical Billers expect in 2023?
With the release of Medicare Physician Fee Schedule (MPFS) Final Rule this November, Traditional MIPS also went through notable changes for CY2023. In this rule CMS updated us about MIPS framework and it’s each distinctive categories post COVID-19 PHE.
The Merit-Based Incentive Payment System (MIPS) is the default Quality Payment Program (QPP) participation pathway for most providers and clinicians. MIPS is composed of four performance categories, which contribute a specified weight to the overall MIPS final score:
- Quality
- Cost
- Improvement Activities
- Promoting Interoperability
Each MIPS performance category contributes a specified weight to the MIPS final score
Participants (individual/group) can receive positive, neutral, or negative payment adjustments based on their MIPS final score.
- If a participant score below the decided performance threshold (18.76 -74.99) or (0 - 18.75 points) for the performance year, negative payment adjustment (negative -9%) will be made as a penalty.
- If a participant score above the decided performance threshold (75.01 – 100) for the performance year, positive payment adjustment (positive +9%) will be awarded as an incentive.
- If a participant is eligible to report MIPS in a performance and chooses not to, negative payment adjustment (negative -9%) will be made as a penalty.
- If a participant is eligible to report MIPS in a performance and manages to score only at peak performance threshold (75 points), neutral payment adjustment of 0 percent will be made.
If it is not your first time participating in MIPS, it’s very well known that gearing up for this reporting process can take time. These coming months are very crucial if you want to participate in MIPS and get things started well in time. Even though discussing MIPS program can easily take a day or so, in this short article we go steadily through pre and post PHE changes made by CMS for the performance year 2023.
How was MIPS impacted by COVID-19 PHE?
During CMS proposed and approved Extreme and Uncontrollable Circumstances exclusion for clinicians impacted by COVID-19 PHE circumstances. Along with many other flexibilities and relaxation made available during COVID-19 PHE also came neutral payment adjustments as well as delayed penalties and incentives during performance years 2021 and 2022.
In 2023, however, the implantation for MIPS program is going to be resumed for performance year 2023, with up to 9 percent penalties and bonuses for up to half of eligible clinicians. Following this pattern, the consecutive performance year will determine clinicians Medicare Part B payments in the Payment year 2025.
Changes made for Merit-Based Incentive Payment System (MIPS) in 2023:
Because of the ongoing COVID-19 PHE, CMS proposes to use 2019 data as the basis for setting the CY 2023 performance threshold at 75 points, which it anticipates would subject approximately one-third of MIPS eligible clinicians to negative payment adjustments for the CY 2023 performance period. This is a significant increase from the 60-point threshold in the 2021 performance year. Exceptional Performance is set to be retired.
Following are the CMS proposed category-based changes for 2023:
Quality:
CMS finalized a total of 198 quality measures for the 2023 performance period which reflect:
- CMS proposes to increase the data completeness criteria threshold from 70 percent to 75 percent starting with 2024 performance.
- CMS proposes modifications to the quality measure set. Which included changes measure meeting criteria for larger practice (>15 clinicians), for data completeness, the performed measures would be scored out of 10 (1 to 10) as compared to be scored out of 3 (1-3) point scale. Smaller practices (<15 clinicians) will still be scored out of 1-3 for measures without a benchmark or measures that don’t meet minimum case requirements (<20 cases).
- Among other changes, CMS proposes to designate all health equity quality measures as high priority measures and seeks feedback on adding additional health equity quality measures, as well as adding questions related to health disparities and price transparency to the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey.
- Moving forward, CMS proposes that administrative claims measures (only) would be scored using performance year data (as opposed to a prospective benchmark from past data).
- Finally, CMS seeks feedback on updating the complex patient bonus to account for health equity and/or safety net providers.
Cost:
- CMS proposes methodological updates to the Medicare Spending Per Beneficiary measure.
- As per, 2022 performance year, CMS proposes to award a small amount of credit for cost improvement, capped at 1% of the cost category score.
- No other significant changes were proposed.
Improvement Activities:
There are no major changes to the MIPS Improvement Activities (IA) category other than updates to the IA inventory. CMS intends to retire and modify a handful of activities to avoid duplication.
- Four proposed new IAs activities, including Create and Implement a Language Access Plan (high-weighted) and COVID-19 Vaccination for Practice Staff (medium-weighted).
- Five changes/modification proposed to existing IAs, including Use of QCDR data for ongoing practice assessment and improvements.
- Five proposed removals, including use of QCDR for feedback reports that incorporate population health (high-weighted) and Consultation of the Prescription Drug Monitoring program.
Promoting Interoperability:
CMS proposes several measure-specific changes for this category, including:
- Query of Prescription Drug Monitoring Program (PDMP) measure is mandatory now with slight modification (inclusion of Schedule II, Schedule III, and IV (opioid) drugs).
- Health Information Exchange (HIE) Objective has an alternative option for reporting through Trusted Exchange Framework and Common Agreement (TEFCA) measure (requiring a yes/no response) .
- Public Health and Clinical Data Exchange Objective levels has been consolidated increased form 10 points to 25 points
- Provide Patients Electronic Access to Their Health Information measure has been decreased form 25 points to 10 points
CMS would require active engagement on each measure and require clinicians to report their level of engagement through data validation. Starting next year, automatic reweighting policy for the PI category for nurse practitioners (NPs), physician assistant (PAs), certified registered nurse anesthetist (CRNAs) or clinical nurse specialists (CNSs) has also been proposed to be discontinued.
Performance Year 2023 MIPS Value Pathways
Beginning with the 2023 performance year, CMS will make the following seven MVPs available as a voluntary MIPS participation pathway. MVPs are composed of quality measures (including one outcome measure [or high-priority measure, if the outcome measure isn't applicable]), improvement activities, and cost measures relevant to the condition, specialty, or patient population.
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 can be an exciting as well as challenging way to improve and promote good quality healthcare standards that the patient deserves. Participation in MIPS with maximum effort might not go in vain as the Healthcare Providers can implement better healthcare industry standards as well as incentivize in this process of learning and earning.
It is the most suitable time to say, the desired and eligible participants start preparing for CY2023 MIPS as we head into next year. Given the recent PHE challenges, it can be rewarding to participate and avoid penalties.
Subscribe to Our Newsletter!
Subscribe to Our Newsletter!
Enter Your Email Address. We Promise We Won't Spam You
Relevant Articles
Categories
Informational
Educational
Medical Billing Software
Follow Us