Healthmonix Advisor

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. 

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Physician Fee Schedule (PFS) Final Rule which governs MIPS and other quality payment programs. Anticipated changes were made to MIPS, making the program more challenging in 2022 and signaling additional changes to the program in coming years.

With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Final Rule, CMS has demonstrated that MIPS will be both financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond.

With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Proposed Rule, MIPS participants find themselves wrestling with lingering disappointment from participation in the program in previous years, and resistance to the idea that MIPS will be financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond.    

This is the second in a series of blog posts on the 2020 payment adjustment and the 2022 Proposed Rule, that will address this sense of disappointment and show how the future of MIPS will contain much more rigorous program requirements and create greater financial rewards.  To see financial and program success, you will need to be prepared to meet the new challenges.  We have the guidance you need to succeed in 2021 and beyond.    

The last 90 days of the year. Many might be ready to say goodbye to 2020 as a year filled with challenges, adjustments and ever-shifting expectations in our personal and professional lives. For those clinicians who are eligible for participation in the Merit-Based Incentive Payment System (MIPS), the last 90 days of the year also represents the beginning of some measurement periods and the final opportunity to improve in others.

The Centers for Medicare & Medicaid (CMS) is working rapidly to update policies and allow healthcare providers to flexibly apply best practices in response to the COVID-19 pandemic.  Programs such as Hospitals without Walls and the existing Patients over Paperwork have been deployed.  Removal of barriers have resulted in exponential growth of telehealth and remote patient monitoring.   Advanced payments to healthcare providers are being provided to counter the effects of changing patterns of healthcare use,  reduction in elective procedure, increase in ICU utilization and other ongoing unanticipated changes.

In our last blog we gave an overview of the MIPS Quality Performance Category and discussed its reporting requirements. This week, we'll look more in-depth at how this category will be scored for the 2019 performance year.

The CY 2019 Medicare Physician Fee Schedule Final Rule involves a slew of regulatory changes that will apply to the 2019 performance year. Of course, wading through the final rule to find and understand the most important features of the policy can be grueling; but you’re in luck, because we’ve already done it so you don’t have to! In today’s blog, we’re focusing on the MIPS Quality Performance category.

As laid out in the 2019 MACRA final rule*, one of the ways CMS hopes to expand participation options in the program’s third year is by offering certain facility-based clinicians, if they participate as a group, the option to use facility-based Quality and Cost performance measures. CMS expects to release a facility-based scoring preview for this option, which does not require any data submission, in Q1 of 2019. In today’s blog, we’ll take an in-depth look at the details of facility-based scoring and how it will be applied.