Proposed Rule for MIPS 2023 Performance Year: Quality Category and MVPs

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The Proposed Rule for the 2023 Performance Year was released in late July. You are encouraged to comment on any of the proposed changes that may negatively impact your practice – either in reimbursement or increased administrative burdens.

As a part of a recent webinar, the Quality Reporting Engagement Group highlighted the proposed changes to the Merit-based Incentive Payment System (MIPS) program for the 2023 Performance Year.

Quality Category

For the Quality measure benchmarks, the Centers for Medicare & Medicaid Services (CMS) is removing the three-point floor for measures that can be scored against a benchmark. They can now receive between one and 10 points. They also will remove the three-point floor for measures without a benchmark. By removing the floor in that second instance, some measures will receive zero points, although small practices will continue to receive a minimum of three points.

The data completeness threshold will remain at 70 percent in 2023. CMS will sunset the Web Interface as a collection type and submission type for traditional MIPS. The interface will remain available as a collection type for ACOs under the Medicare Shared Savings Program for the APM Performance Pathway.

New measures proposed under the Quality category for 2023 include: Screening for Social Drivers of Health, Kidney Health Evaluation, Adult Kidney Disease: ACE/ARB Therapy, and Adult Immunization Status. Some of the measures proposed for removal are: Prevention of Central Venous Catheter – Related Bloodstream infections; Diabetes – Medication Attention for Nephropathy; Preventive Care and Screening – Influenza Administration; and Pneumococcal Vaccination Status for Older Adults. (NOTE: many of these measures are used routinely by practices who work with the Quality Reporting Engagement Group team). Practices are encouraged to review their current measures and evaluate the impact losing measures may have on their performance in future years. They should consider alternate measure options for replacement and evaluate workflow changes, if necessary. The complete list of measures proposed for removal can be found in Table Group C of the Proposed Rule.

MIPS Value Pathways (MVPs)

MVPS are optional for the 2023 Performance Year. CMS has stated that their intent is to move the MIPS program toward MVPs but has not finalized the plan for sunsetting Traditional MIPS. Practices are encouraged to comment, no matter their opinion.

CMS is proposing to identify Medicare Part B claims as the data source for determining specialty types for both single specialty and multispecialty reporting.

There are seven MVPs that will begin in 2023, which were finalized in 2022. In addition, CMS is proposing five new pathways for the 2024 Performance Year. These include:

  • Advancing Cancer Care
  • Optimal Care for Kidney Health
  • Optimal Care for Neurological Conditions
  • Supportive Care for Cognitive-based Neurological Disorders
  • Promoting Wellness

CMS has noted that they will post the draft MVP candidates to the Quality Payment Program (QPP) website for a 30-day public feedback period. Practices are encouraged to comment. They will review the recommendations and determine any changes before the proposed rulemaking. In the calendar year 2022, recommendations can be made by email at PIMMSMVPSupport@gdit.com. In 2023, CMS is proposing an annual public webinar to discuss potential revisions.

The Quality Reporting Engagement Group partners with practices from helping choose the performance measure activities to submission, and even during an auditing process. With a combined 30+ years of experience, their team of experts understands regulatory changes and supports your Eligible Clinicians in successfully meeting MIPS measures. For answers to any questions, contact the team at QREG@intrinsiq.com.