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.
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
- 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:
- CMS is removing the three-point floor for measures that can be reliably scored against a benchmark (meet case minimum and data completeness). These measures will receive 1–10 points.
- This policy doesn’t apply to new measures in the first two performance periods available for reporting.
- For measures without an available benchmark (historical or performance period):
- CMS is removing the three-point floor for measures without a benchmark, even when data completeness and case minimum criteria are met. These measures will receive zero points. Small practices will continue to earn three points.
- This policy doesn’t apply to new measures in the first two performance periods available for reporting or to administrative claims measures.
- For measures that don’t meet case minimum:
- CMS is removing the three-point floor for measures that don’t meet case minimum. These measures will earn zero points. Small practices will continue to earn three points.
- This policy doesn’t apply to new measures in the first two performance periods available for reporting or to administrative claims measures. Measures calculated from administrative claims are excluded from scoring if the case minimum is not met.
Promoting Interoperability Performance Category
The CMS proposes to:
- Discontinue automatic reweighting for the following clinician types: nurse practitioners, physician assistants, certified registered nurse anesthetists and clinical nurse specialists;
- Continue automatic reweighting for the following clinician types: clinical social workers, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists and registered dieticians or nutrition professionals;
- Modify the levels of active engagement for the Public Health and Clinical Data Exchange Objective measures;
- Make the query of Prescription Drug Monitoring Program (PDMP) measure a required measure;
- Add a third option for satisfying the health information exchange (HIE) objective in the Promoting Interoperability category: Participation in the Trusted Exchange Framework and Common Agreement (TEFCA); and
- Adjust some of the individual Promoting Interoperability measures’ maximum points.
Improvement Activities Performance Category
The CMS is proposing to update the improvement activities inventory by:
- Adding four new improvement activities;
- Modifying five existing improvement activities; and
- Removing six improvement activities.
- Note that one activity proposed for removal—IA_PSPA_6: Consultation of the Prescription Drug Monitoring Program—has been a popularly submitted improvement activity through the RISE registry.
MIPS Value Pathways (MVPs) Proposals
The CMS proposes:
- Minor updates to the Advancing Rheumatology Patient Care MVP;
- To broaden the opportunities for the public to provide feedback by posting draft versions of MVP candidates on the QPP website; and
- Adding five new MVPs and revising the seven previously established MVPs that would be available beginning with the 2023 performance year.
The following policies were previously finalized in the CY 2022 PFS Final Rule and apply in the 2023 performance period:
- The Advancing Rheumatology Patient Care MVP will be available for reporting through the RISE registry.
- MVP participation remains voluntary. Clinicians may choose their preferred reporting pathway.
- A multi-specialty group can participate in an MVP in the first three years of the pathway. By 2026 reporting, each specialty within the group will need to form a subgroup and report on specialty-specific measures.
- MVP and subgroup registration will be open between April 1 and Nov. 30, annually.
- Note: Subgroups will be assigned a unique identifier different from both TIN and NPI by the CMS upon completion of registration.
What Does This Mean for Your Practice?
Practices are encouraged to contact RISE staff at [email protected] with any questions regarding how they will be affected by these proposed policies. Effects on practices will vary depending on the practice’s eligibility and reporting factors, such as special status and hardship exceptions.
The ACR will comment on the proposed rule on behalf of the specialty. Members may submit their comments to the ACR Advocacy team or comment to the CMS directly. The proposed changes are not finalized until the CMS announces the final rule, expected around November 2022. At that time, the ACR will review and evaluate the final rule and provide more information.
Additional Resources
These are key takeaways from the proposed rule; this is not a comprehensive list of all proposed changes. Additional information is available from the QPP.
Questions?
Contact the Quality Payment Program at (866) 288-8292 or [email protected].
The ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE team at (404) 633-3777 or [email protected].
