On July 14, the Centers for Medicare & Medicaid Services (CMS) issued its proposed policies for the Quality Payment Program (QPP) via the 2024 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rule Making (NPRM), which includes the 2024 Quality Payment Program (QPP) proposed rule.
The CMS continues its pattern of layering on refinements to the QPP and raising the standards for performance in this proposed rule. Following the end of the public health emergency (PHE) in May, the CMS has noted that it is looking forward to getting the QPP back on track with the path that was planned before the pandemic. The ACR RISE registry staff reviewed the proposed rule and highlighted key takeaways and proposed policies for the 2024 Merit-Based Incentive Payment System (MIPS) reporting period below.
Performance Category Weights
- Quality: 30% (no change from CY 2023)
- Promoting Interoperability: 25% (no change from CY 2023)
- Improvement Activities: 15% (no change from CY 2023)
- Cost: 30% (no change from CY 2023)
Performance Threshold
The CMS is proposing to increase the performance threshold from 75 to 82 points, which aligns with its goal of increasing practices’ return on their investment in MIPS participation by providing the opportunity to achieve a higher positive payment adjustment. This increase would apply to Traditional MIPS, MIPS Value Pathways (MVPs) and the Alternative Payment Model (APM) Performance Pathway (APP).
Quality Performance Category
The CMS proposes to:
- Offer 200 quality measures for the 2024 performance period; all currently available rheumatology-specific QPP measures are included in the proposal.
- Note that the CMS is proposing to:
- Remove QPP111: Pneumococcal Vaccination Status for Older Adults, because it is duplicative to measure Q493: Adult Immunization Status. QPP111 is being replaced by Q493: Adult Immunization Measure in all applicable MVPs, including the Advancing Rheumatology Patient Care MVP.
- Partially remove QPP128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan from the MIPS quality measure inventory. This measure is commonly reported via Traditional MIPS through the RISE Registry. It is proposed for removal for Traditional MIPS but retained for MVP use only; however, it is not part of the Advancing Rheumatology Patient Care MVP.
- Keep the previously finalized data completeness threshold the same at 75% for the 2024 and 2025 performance periods for electronic clinical quality measures (eCQMs), MIPS CQMs, Medicare Part B claims measures and qualified clinical data registry (QCDR) measures.
- Note that for the 2023 performance period, the data completeness threshold was 70%.
- Increase the data completeness threshold for subsequent performance periods for eCQMs, MIPS CQMs, Medicare Part B claims measures and QCDR measures:
- 75% for the 2026 performance period
- 80% for the 2027 performance period
- Modify the criteria used to assess ICD-10 coding updates:
- Eliminate the automatic 10% threshold of coding changes that triggers measure suppression or truncation;
- Assess the impact of coding changes on a case-by-case basis; and
- Assess each collection type separately of a given measure in order to determine the appropriate action to take for a measure affected by an ICD10 coding update.
- Note that the CMS is proposing to:
Promoting Interoperability Performance Category
The CMS proposes to:
