To meet the Quality performance category requirements, a MIPS eligible provider, group, or virtual group can report:

• 6 quality measures (including at least one outcome measure or high priority measure in absence of an applicable outcome measure) for the 12-month performance period;OR
• A defined specialty measure set (if the measure set has fewer than 6 measures, all measures within that set need to be submitted);OR
• All quality measures included in the CMS Web Interface, a collection type available to registered groups or virtual groups with 25 or more eligible providers.

Data Completeness

For 2023, the data completeness requirement is 70%. Providers need to report performance or exclusion/exception data for at least 70% of patients or encounters that are eligible for the measure’s denominator.

What’s New with Quality in 2023?

• The quality performance category weight remains 30% for individual MIPS eligible providers, groups, and virtual groups participating in traditional MIPS.
• There are no bonus points for reporting additional outcome and high priority measures, or end-to-end electronic reporting.
• CMS finalized a total of 198 quality measures for the 2023 performance period.
• The definition of a high priority measure is expanded to also include health equity-related quality measures.
• The 3-point floor is removed for measures that can be reliably scored against a benchmark (i.e., those that meet the data completeness and case minimum criteria).

What’s New with Promoting Interoperability (PI) in 2023?

• Addition of 4 new IAs, 2 of which are related to promoting health equity.
• Modification of 5 existing improvement activities, 11 of which address health equity.
• Removal of 6 existing improvement activities.

For the 2023 PY, the Cost category is included in the final score and is weighted for 15% of the final score. Cost will be calculated directly by CMS and therefore no submission will be required.

• Reporting period will be for the full PY in 2023.
• Individual eligible providers or groups will be scored on 25 measures included in the Cost performance category.
• Medicare Spending per Beneficiary (MSPB), Total per Capita Cost measure for all attributed beneficiaries (TPCC) and 23 episode-based cost measures.
• CMS will calculate Cost category score based on administrative claims data.

What’s New with Cost in 2023?

CMS has  established a maximum cost improvement score of 1 percentage point out of 100 percentage points available for the cost performance category, starting with the 2022 performance period.

• Clinical social workers
• Small practices
• No reweighting for certified nurse midwives.

Merit-Based Incentive Payment (MIPS) Background

The Centers for Medicare and Medicaid Services (CMS) introduced the Quality Payment Program in 2015 with two tracks: MIPS and Advance Payment Model (APM).

In MIPS, performance-based payment adjustments are made for the services provided to Medicare patients based on a Final Score. Performance is measured across 4 areas – Quality, Improvement Activities (IA), Promoting Interoperability (PI) and Cost.

As the MIPS program has matured, the difficulty of avoiding payment penalties has been steadily increasing. Also, clinicians and stakeholders have expressed that MIPS is overly complex.

What are MVPs?

MVP is a conceptual participation framework applying to future proposals beginning with the 2023 performance year. The MVP framework aims to align and connect measures and activities across the Quality, Cost, PI, and IA performance categories of MIPS for different specialties or conditions. MVPs are based on a specialty, medical condition, or episode of care and are established through the CMS rule- making process.

How are MVPs going to make reporting more meaningful?

Traditional MIPS reporting can be confusing. Scoring logic and the reporting requirement of each category are unique. In addition, there are many measures and activities to choose from, many of which are not relevant to a clinician’s specialty.

The introduction of MVPs is a landmark change aimed at reducing the reporting burden while also moving away from certain activities and measures. Reporting on an aligned set of performance measure options relevant to a clinician’s scope of practice is more meaningful to clinicians, allows patients and caregivers to make more informed choices using comparative performance data and places greater emphasis on patient care. MVPs also reduce barriers to APM participation and support the transition to digital quality measures.

For multispecialty groups, the MVP subgroup reporting option provides a way to report performance information meaningful to the various specialties and teams within the group.

Who can report MVPs?

For the 2023 MIPS performance period, MVPs may be reported by individual MIPS eligible clinicians, multi-specialty groups, single-specialty groups, subgroups, or APM Entities.

Population Health Measures

First steps to prepare for MVP reporting

MVPs will be available for submission in performance year 2023. Being informed about the nuances of the evolution of MVPs will enable clinicians to choose the best possible option for their reporting, aiming to earn positive payment adjustments, simplify the reporting and enable better focus on patient care.

1. CMS already finalized 12 MVPs in 2023 Final Rule. Identify whether any of them are related to your specialty:
• Advancing Cancer Care
• Optimal Care for Kidney Health
• Optimal Care for Patients with Episodic Neurological Conditions
• Supportive Care for Neurodegenerative Conditions
• Promoting Wellness
• Advancing Care for Heart Disease
• Optimizing Chronic Disease Management
• Advancing Rheumatology Patient Care
• Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
• Improving Care for Lower Extremity Joint Repair
• Patient Safety and Support of Positive Experiences with Anesthesia
• Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
2. If you identify a relevant MVP, check if you are already submitting for the quality measures. If so, how do your previous year’s scores look like? Then look at the listed IAs to see if you are already reporting on them.
3. Ideas for an additional MVP that supports meaningful measurement of a specialty, condition or public health priority that is meaningful to patient care can be brought to CMS as they have published guidelines for Candidate Development and Submission.
4. It is expected that CMS will publish more MVPs in the proposed rule 2023. After reviewing if any of the MVPs pertain to your specialty/practice, send your comments to CMS.
5. Remember that all PI measures are mandatory unless exceptions are claimed. Review and update your health-IT systems as per the requirements.