What you need to know for MIPS submissions in 2023

Not reporting your Merit-based Incentive Payment System (MIPS) performance data can have a significant impact on your annual revenue – and with costs continuing to climb, how can you afford not to get the best possible reimbursement in your claims two years from now? Yet, you need to be aware of the changes put in place by the Centers for Medicare & Medicaid Services (CMS) for your processes to be effective.

The 2023 Quality Payment Program Final Rule did not have significant changes from the proposed rule, but practices should be aware of some changes that might affect their processes in the coming year.

What was finalized under the Quality category:

• For the Quality measure benchmarks, the 3-point floor was removed. Scoring against the benchmarks is now 1-10 points. The 3-point floor for measures without a benchmark were also removed. Those measures receive 0 points, but small practices can continue to earn 3 points.
• Data completeness remains at 70 percent this year but will move to 75 percent in 2024.
• The CMS Web Interface will sunset and will only be available to those reporting for the Medicare Shared Savings Program.
• Not every practice or even same specialties report on the same measures. Practices are urged to go to the 2023 Final Rule to see what Quality measures were added and which were removed (you can review Table Group C which is embedded in the Final Rule). It may help to check with your specialty society to see what they suggest.

There were some substantial changes to the Promoting Interoperability category:

• CMS discontinued reweighting for the Eligible Clinicians (EC) – Nurse Practitioners, Physician Assistants, Certified Nurse Anesthetists and Clinical Nurse Specialists – in 2023. They will need to report with a group or as an individual. Other ECs will continue to receive automatic reweighting.
• When participating in MIPS at the APM entity level, CMS will allow APM Entities to the APM Entity level but continue to have the option to report this category at the individual or group level.
• For the Public Health & Clinical Data Exchange, MIPS ECs may spend a year in the newly combined (Options 1 and 2) option titled “Pre-Production and Validation,” but must progress to Option 3 – “Validated Data Production.” This is no longer just a yes/no answer, but your ECs must submit their level of active engagement.
• The Query of Prescription Drug Monitoring Program is a required measure. While in previous years, there were bonus points associated with this measure, it is not required and was not previously required but will be starting in 2023 and on.
• CMS added a third option to satisfy the Health Information Exchange (HIE) objective with participation in the Trusted Exchange Framework and Common Agreement (TEFCA).

There were some changes in the Improvement Activities category:

• CMS added four new improvement activities, modified five existing and removed six existing. We recommend that you check the 2023 Inventory List in QPP when updated for the list of all activities that are available.

Five new MIPS Value Pathways were finalized, for a total of 12 available for reporting.The new MVPs include: Advancing Cancer Care, Optional Care for Kidney Health, Optimal Care for Neurological Conditions, Supportive Care for Cognitive-Based Neurological Disorders and Reporting Wellness.  You can review the entire list on https://qpp.cms.gov.

CMS is also soliciting feedback from healthcare providers on the development of MIPS Value Pathways.  While CMS makes the final decision on potential MVPs, they will consider emailed recommendations and may hold public webinars for additional feedback.

The Quality Reporting Engagement Group (www.intrinsiq.com/mips-consulting) spends hours reviewing the annual changes for MIPS submissions.  With their 30+ years of combined industry experience, they understand how to help your practice - whether it’s deciding what measures work for you, helping you with your processes, or just taking the mounds of data and helping you with your submission, they are ready to help. If you have questions or are looking for help in just submitting your data, reach out to them at  QREG@intrinsiq.com.