A Comprehensive Timeline Review of MIPS 2023 Reporting

Following the systematic plan of QPP reporting, we are now at the end of the MIPS 2023 performance year. We already know the MIPS has strict timelines and deadlines that more or less remain the same. A MIPS participant moves from one benchmark to another throughout their participation. And CMS releases news updates regarding every stage. These updates are available on the QPP’s official website. All participants can make the necessary preparations accordingly and have equal access to them.

Before entering FY 2024, let’s review what milestones in MIPS 2023 reporting we’ve covered. This will tell us at which stage we are in our MIPS journey. And we will be able to identify our deficient areas, which we need to improve in the future.

MIPS 2023 Timeline Overview

What has gone on with MIPS 2023 Reporting?

For any confusion, let’s just start from the very beginning phase of MIPS 2023 reporting. It marks the time when CMS presented the 2023 PFS final policy on its official portals.

❖    November 2022 | PFS 2023 Final Policy

In the first week of November 2022, CMS presented the final rulemaking policy for MIPS 2023 reporting. Days back in the following year, participants got a PFS-proposed rule by CMS. As it is the proposed policy, it is not the final policy. In fact, it may get modified, and the final policy seems to be different. The proposed rule only gives the participants an idea of the new changes coming their way. Therefore, they can revise their strategies for MIPS 2023 for any situation in the future.

❖    December 2022 | MIPS Eligibility Information Updates

Late in December, CMS released the updated status for MIPS-eligible participants. At this time, participants get eligibility in two forms:

• One is the initial eligibility for performance year 2023, starting on January 1, 2023.
• Second, the updated (final eligibility) before the end of the 2022 MIPS performance period (December 31, 2022). Afterwards, the MIPS 2022 reporting phase will start from January 1, 2023, to March 2023.

To check your MIPS eligibility, you must directly enter your NPI in the Participation Status Tool. Further, following the array of steps, you will get the required information.

❖    January 1, 2023 | Beginning of Performance Year 2023

From this date on, the new performance year began. So, all clinicians who had initial eligibility for MIPS 2023 started participating in the program. They had 12 months, from January 1 to December 31, to collect their MIPS performance data. Following two subsequent segments, they got their final MIPS eligibility at the end of that year.

❖    April 3, 2023 | Registrations for CAHPS for the MIPS Survey and MVPs

CAHPS stands for Consumer Assessment of Healthcare Providers and Systems (CAHPS) for the MIPS Survey. The MIPS participants who wanted to administer the CAHPS survey enrolled in the registration. The deadline for registration was June 30, 2023. So, all MIPS participants have ample time for registration.

CY 2023 is the first year for MVPS reporting as a voluntary MIPS reporting option. So, those who wanted to avail themselves of this option had registered themselves by November 30, 2023. During this period, they nominate themselves as MIPS participants, reporting as a subgroup.

❖    Spring/Summer 2023 | MIPS Exception Application Window Open

It’s the time of year when CMS accepts Exception applications for MIPS participants. Like all other things, to be eligible for exceptions in MIPS, we have certain criteria. CMS decides eligibility using this criterion very strictly. There were two exception application options available to MIPS 2023 participants:

1. Extreme and Uncontrollable Circumstances Exception (any or all performance categories)
2. Hardship Exception to the PI Performance Category Only

Note that the deadline for applying is January 2, 2024.

❖    June 30, 2023 | CAHPS for MIPS Survey Deadline

It’s the last date for CAHPS to register for the MIPS survey. The registration window opens for MVPs and CAHPS registration at the same time; therefore, CMS provided some specifications to avoid confusion. For those who want to register for both, they must complete their MVP registration first before June 30.

❖    July 2023 | APM Eligibility Updated (Snapshot Date: March 31)

MIPS APM participants got their eligibility information for the APM snapshot on March 31. In order to remain a MIPS participant, it is necessary to not get QP status at any stage. So, those MIPS participants who got QP status faced an exception from MIPS.

❖    October 2023 | APM Eligibility Updated (Snapshot Date: June 30)

MIPS APM participants got their eligibility information for the APM snapshot date of June 30.

❖    October 3, 2023

For Promoting Interoperability and Improvement Activities, MIPS 2023 participants had a 90-day continuous period. During this time, they record their performance in the two categories. October 3 is the last date to start their 90-day period.

❖    November 30, 2023 | MVPs Registration Closed

What do we still have in our Hands?

MIPS 2023 participants have accomplished several milestones in their performance period. Now, moving swiftly towards the end of the 2023 performance period, preps for 2024 have commenced. Let’s see what part of MIPS 2023 we are left with!

❖    December 2023 | Eligibility Information Updates

It is time to get the final eligibility updates. This time, clinicians will get the final eligibility for MIPS 2023 before entering the 2023 reporting phase. Likewise, CMS will also update the information regarding initial eligibility for PY 2024.

MIPS APM participants will get their updated status for the APM snapshot on August 31.

❖    December 31, 2023 | End of MIPS 2023 Performance Period

❖    January 2, 2024 | Submission Window Open

This marks the time for the closure of the QPP Exception Application Window. From this date on, the submission window for the 2023 performance period opens. MIPS 2023 participants will submit their reporting data to CMS in appropriate forms.

❖    March 2024 | APM Eligibility Updated (Snapshot Date: December 31)

MIPS APM participants will get their eligibility information for the APM snapshot on December 31.

❖    April 1, 2024 | Submission Window Closes

Mark it in the calendar as the date of closure of the submission window for the 2023 performance year.

❖    Late Spring/Early Summer 2024 | Final Score Perview Period

During this preview period, the MIPS 2023 participants will get access to their final score. On the basis of this score, CMS will determine the 2025 payment adjustments.

❖    Late Summer 2024 | Performance Feedback & Payment Adjustment Info

Payment adjustment information, along with performance feedback, is a crucial step. It helps clinicians determine what deficiencies they have and where their performance falls. With the help of 2023 performance feedback information, they can improve their MIPS 2024 performance.

Also, CMS provides the target review just after releasing the payment adjustment information. After completing the 60-day period, the window will close in the fall of 2024.

❖    January 1, 2025 | Payment Adjustment Year

At last, MIPS 2023 participants will get their payment adjustments based on their scores until December 31, 2025.

Endnote

That’s all about MIPS 2023 reporting. If you need assistance at any stage of your MIPS reporting, you can take advantage of our MIPS consulting services. Especially during the submission period, we can be your partner in MIPS as we are an MIPS-qualified registry. We can help you with the documentation process.

Hope you find this blog useful for your MIPS journey ahead. Place your queries in the comment section below; we will try to answer them all.