What are CY 2024 Policy Updates For MIPS Reporting?

High time in the MIPS reporting season! Kudos to all MIPS participants who retained their eligibility for MIPS 2023 throughout. Soon, the 2023 performance period will end, and clinicians will enter the reporting phase. However, moving one step forward, CMS has now released the PFS final rule for MIPS 2024. So, it’s high time for eligible MIPS participants to gear up for PY 2024 and revise their strategies. Before that, you must review the CY 2024 policy updates that have undergone regulatory modifications. With the intent of tracking back to the original MIPS path, the 2024 reporting rule retains its flexibility. So, the PFS final rule for MIPS 2024 encloses comprehensive details on policy changes.

[Note: P3 Care, as a MIPS-qualified registry, presents your series of blogs on MIPS final rule updates for CY 2023. So, this is ‘Part I’ of our CY 2024 MIPS policy changes.]

In this blog, we will cover the details related to the quality and cost performance categories of the MIPS program. We know that there are three reporting options for MIPS participants, namely:

Traditional MIPS
MIPS Value Pathways (MVPs)
Alternative Payment Model (APM) Performance Pathway (APP)

CMS has made revisions to the MIPS policy for the three reporting options. So, we will explain every policy change applicable to these three reporting options collectively.

Let’s dig in without further delay!

Quality Performance Category

Without a doubt, the category has retained its proportion in MIPS final scoring (30%).

Quality Measure Inventory (for MVPs and Traditional MIPS)

We still have 198 quality measures in total, excluding QCDR measures. These measures are customarily approved outside the rulemaking process. Overall, CMS has added 11 quality measures and excluded 11. Likewise, three quality measures are partially removed, and 59 existing ones underwent substantial changes.

Collection Types

In the past, ACOs have encountered data aggregation and patient matching issues when reporting eCQMs and MIPS CQMs under the APP. Therefore, the new rule announces the establishment of a new collection type, particularly for ACOs. This new collection type is named ‘Medicare ACO’.

Medicare CQM requires MSSP participants to report data on the ACO’s Medicare beneficiaries. (Medicare fee-for-service beneficiaries are those that meet the beneficiary eligibility criteria for Medicare CQM at § 425.20.)

Data Completeness

The data completeness criteria for quality measure reporting are the same as they were in MIPS 2023. The MIPS 2024 final policy sets a 75% data completeness threshold for collection types. Thus, there is no distinction applied to Medicare CQMs. Also, CMS has clearly declared this threshold for Medicare CQMs for the 2024, 2025, and 2026 performance periods.

CAHPS for the MIPS Survey

Spanish survey translation is possible for Spanish-preferring patients. MIPS participants (groups, virtual groups, subgroups, and APM entities) can contact their survey vendors to do so. They will administer the survey in Spanish and other applicable translation options.

ICD-10 Coding Changes

ICD-10 codes update with time. For the MIPS 2023 quality measure, there were criteria to access ICD-10 coding changes. According to previous policy, measure suppression or truncation was possible as per the automatic 10% threshold for coding changes. Anyhow, CMS has finalized the following in the PFS final rule for MIPS 2024:

Elimination of the automatic 10% threshold for coding changes
New criteria: access coding changes on a case-by-case basis, i.e.,
- Assessment becomes necessary when changes are substantive.
  By doing so, we will check for changes impacting the numerator, denominator, exclusions, exceptions, or other elements. So, we can then determine the coding change scope and intent of the measure.
Evaluation of each collection type for a certain measure independently
(It will help you identify the necessary steps when addressing the impact of an ICD-10 coding update on that measure.)

Cost Performance Category

CMS automatically assigns the cost category scores for any applicable cost measures. But for the PFS final rule of MIPS 2024, CMS has updated the score calculation and scoring policies.

Cost Improvement Scoring (Calculation)

The current MIPS policy requires the cost improvement score calculation at the measure level. In other words, CMS has conclusively revised the calculation methodology for cost performance at the category level, commencing with the CY 2023 performance period and extending into the 2025 MIPS payment year, with the deliberate exclusion of statistical significance.

This technique assures both mathematical and operational viability for cost-performance scoring improvements. Moreover, it conforms to the standard operating procedure of CMS for rating enhancements in the quality performance category.

Conclusion

That’s all about the MIPS 2024 policy updates under its two essential performance categories: cost and quality. These two categories have a significant role in determining the final score of MIPS. The measures reported in these categories influence the provider’s performance in other categories as well. Therefore, get to know the policy changes in these categories in detail. For further information, feel free to use our MIPS consulting services. As a MIPS qualified registry, our team of experts is eager to help you succeed in MIPS reporting.