On July 7, the Centers for Medicare & Medicaid Services (CMS) issued its proposed policies for the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Proposed Rule for the 2023 performance year and beyond.
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In this proposed rule, the CMS continues its pattern of layering small refinements to the QPP and raising the standards for performance. No changes are made to performance category weighting or performance thresholds; both reached the MACRA-required levels in 2022. The CMS is proposing to launch the previously delayed Merit-Based Incentive Payment System Value Pathway (MVP) and finalizes more details of that program within the proposed rule. Clinicians should review the rheumatology MVP in detail and assess their interest in participating in the first year of the new pathway. Scoring changes to measures without benchmarks mean all practices should consider the benchmark status of the measures when selecting measures to report.
The ACR RISE registry staff reviewed the proposed rule and highlighted key takeaways and proposed policies in the 2023 Merit-Based Incentive Payment System (MIPS) reporting period below.
Performance Category Weights
- Quality: 30% (no change from CY 2022)
- Promoting Interoperability: 25% (no change from CY 2022)
- Improvement Activities: 15% (no change from CY 2022)
- Cost: 30% (no change from CY 2022)
- Performance threshold at 75 points (no change from CY 2022)
- Note: The 2022 performance year/2024 payment year is the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.
Quality Performance Category
The CMS proposes to:
- Offer 194 quality measures for the 2023 performance period; all currently available rheumatology-specific QPP measures are included in the proposal. Note that the CMS is proposing to remove commonly reported QPP110 and QPP111 from traditional MIPS and make them available through the MVP pathway only;
- Use performance period benchmarks exclusively for scoring administrative claims measures;
- Expand the definition of a high-priority measure to include health equity-related quality measures; and
- Increase the data completeness threshold to 75% for the 2024 and 2025 performance periods. Note that for the 2023 performance period, the data completeness threshold remains at 70%.
The following policies were previously finalized in the CY 2022 PFS Final Rule and apply in the 2023 performance period:
- The CMS Web Interface will sunset as a collection and submission type for traditional MIPS. Any practices using the CMS Web Interface should start assessing other reporting options.
- For measures that can be reliably scored against a benchmark: