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Background: Under the Quality Payment Program (QPP), eligible clinicians face payment adjustments determined by their performance in the Merit-Based Incentive Payment System (MIPS) or choose to participate in the Advanced Alternative Payment Model (APM) track. Those in MIPS see their payments increased, maintained, or decreased based on relative performance in four categories: Quality, Cost, Promoting Interoperability, and Improvement Activities.  

Clinicians participating in an Advanced APM are exempt from MIPS and were initially qualified for a 5% bonus payment. However, after the expiration of the 5% bonus, Congress reauthorized the bonus at a reduced rate of 3.5% for the year 2023. Additionally, the Centers for Medicare & Medicaid Services (CMS) has introduced a new alternative to traditional MIPS known as the MIPS Value Pathways (MVPs), which is a voluntary option for eligible clinicians.

The program continues to evolve at a macro level, as CMS has a vision to move providers out of ‘traditional MIPS’ and into other reporting options such as APP for Shared Savings participants, MVPs for those still in fee for service, and APMs for other provider programs. In addition, CMS continues to pursue the Universal Foundation. Providers need to be prepared for bigger shifts in their quality reporting strategies as CMS aligns programs under the National Quality Strategy.

Below we explore some of the key takeaways from the 2024 PFS Final Rule impacting the QPP program.

In the 2024 Medicare Physician Fee Schedule (PFS) Final Rule released yesterday, CMS is emphasizing getting the Quality Payment Program (QPP) “back on track with the trajectory we had planned before the public health emergency (PHE)”. They’re focused on ensuring that the program resumes its intended progress, which was interrupted during the PHE over the last few years. 

Here's an initial breakdown of what this means. 

Are you ready to jump back into the MIPS program?   

The Centers for Medicare & Medicaid Services (CMS) have released Final Performance Feedback for the 2022 Merit-based Incentive Payment System (MIPS) performance period. We are seeing record maximum incentives of 8.25% for providers who achieved top scores.   

In the 2024 Proposed PFS Rule released in July 2023, CMS outlined a new option for MSSP participants to report quality measures called the Medicare CQM option. CMS created this reporting option to address concerns raised by ACOs and others, while still transitioning ACOs toward digital quality measure reporting. 

Read on to learn more about the new proposed option for MSSP participants. 

With 2022 MIPS preliminary scores available, oncology practices are increasingly seeing how the Cost category negatively affects their overall MIPS scores.  

Before CMS added the Cost category to 2022 MIPS scores, research hinted that oncology and other specialties with higher healthcare costs might face more adverse effects than other specialties. Numerous oncology practices opted for an Extreme and Uncontrollable Circumstances (EUC) exemption for the Cost category in 2022, mitigating the impact of cost measures on them.  

Read on to learn more about how MIPS Cost scores are affecting Oncology practices.