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.
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).
PI Reporting Requirements
What’s New with Promoting Interoperability (PI) in 2023?
CMS is discontinuing automatic reweighting for the following clinician types, beginning with this 2023 performance period:
- Nurse practitioners
- Physician assistants
- Certified registered nurse anesthetists
- Clinical nurse specialists
When participating in MIPS at the APM Entity level (reporting the APP, traditional MIPS or an MVP), APM Entities can choose to report Promoting Interoperability data at the APM Entity level.
PDMP is a required measure beginning with the 2023 performance period.
CMS has added a 3rd option for satisfying the HIE objective for the 2023 performance period, in addition to the 2 existing options.Option 3: Participation in the Trusted Exchange Framework and Common Agreement (TEFCA)
IA Reporting Requirements
The Improvement Activities (IA) performance category focuses on one of the MIPS strategic goals, to use a patient-centered approach to program development that leads to better, smarter, and healthier care.
Improvement Activities are classified into Care coordination, Beneficiary engagement, and Patient safety sub-categories which MIPS eligible providers could select from a list of approximately 106 activities.
MIPS eligible providers or groups can attest to the activities performed for a period of minimum 90 continuous days and qualify for a score in IA category.
At least 50% of the providers (in the group or virtual group) must perform the same activity during any continuous 90-day period, or as specified in the activity description, within the same performance period.
- 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.
Cost Reporting Requirements
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.
Reweighting of Performance Categories
CMS has proposed to discontinue automatic reweighting for the following clinician types beginning with 2023 performance period: Nurse practitioners, Physician assistants, Certified registered nurse anesthetists and Clinical nurse specialists
For 2023 MIPS PY, CMS has finalized redistribution of the performance category weights.
|No Reweighting Needed|
|• Scores for all four performance categories||30%||30%||15%||25%|
|Reweight One Performance Category|
|• No Cost||55%||0%||15%||30%|
|• No Promoting Interoperability||55%||30%||15%||0%|
|• No Quality||0%||30%||15%||55%|
|• No Improvement Activities||45%||30%||0%||25%|
|Reweight Two Performance Categories|
|• No Cost and no Promoting Interoperability||85%||0%||15%||0%|
|• No Cost and no quality||0%||0%||15%||85%|
|• No Cost and no Improvement Activities||70%||0%||0%||30%|
|• No Promoting Interoperability and no Quality||0%||50%||50%||0%|
|• No Promoting Interoperability and no Improvement Activity||70%||30%||0%||0%|
|• No Quality and no Improvement Activity||0%||30%||0%||70%|
- Clinical social workers
- Small practices
- No reweighting for certified nurse midwives.
MIPS Value Pathways (MVPs)
The new concept in 2023
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.
What are the reporting requirements of an MVP?
Foundation Layer Reporting Requirements:
The entire set of Promoting Interoperability measures, as a part of the foundation layer, are included in all MVPs.
Population Health Measures
As part of the foundation layer, at the time of MVP Registration, the Participant must select one Population Health Measure. The score from the selected measure is added to the Quality Performance Category of the MVP.
2 medium-weighted improvement activities OR one high-weighted improvement activity OR PCMH
no submission required
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.
- 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