The rules and requirements have changed each year of the MIPS program. Below is a list of major highlights for the new year:
- Removal of exceptional performance threshold and payment.
- Addition of Tobacco Use quality measure to radiation oncology measure set.
- Payment adjustment is +/-9%.
- Inclusion of level of engagement for each measure in Promoting Interoperability.
- Introduction of MIPS Value Pathways.
Physicians can look up eligibility on the QPP Participation Lookup tool based on their National Provider Identification (NPI) number.
You’re considered a MIPS eligible clinician (i.e., required to report) and will receive a payment adjustment when:
- You’re an eligible clinician type AND
- You enrolled in Medicare before January 1, 2022 AND
- You’re not identified as a QP AND
- You exceed the low-volume threshold.
To exceed the low-volume threshold for the 2023 performance year, you must:
- Bill more than $90,000 for Part B covered professional services under the Physician Fee Schedule (PFS), AND
- Provide services to more than 200 Medicare Part B patients, AND
- Furnish more than 200 covered professional services to Part B Medicare Patients.
These requirements allow for physicians to opt-in to MIPS if they meet at least one of the three criteria. Those opting in will receive the related payment adjustment two years later. Those that do NOT meet any of the criteria can voluntarily report data; however, they will not receive a payment adjustment.
There are many requirements and rules in MIPS, however there is still a large amount of flexibility for participating in the program.
What has historically been referred to as MIPS is now called Traditional MIPS. Under the traditional MIPS, participants select from 200 quality measures and over 100 improvement activities, in addition to reporting the complete Promoting Interoperability measure set. CMS collects and calculates data for the Cost performance category for you, if applicable.
In addition to traditional MIPS, two other MIPS reporting frameworks, designed to reduce reporting burden, are available to MIPS eligible clinicians.
The APM Performance Pathway (APP), is a streamlined reporting framework available beginning with the 2021 performance year for MIPS eligible clinicians who participate in a MIPS APM. The APP is designed to reduce reporting burden, create new scoring opportunities for participants in MIPS APMs, and encourage participation in APMs.
MIPS Value Pathways (MVPs) are subsets of measures and activities, established through rulemaking, that can be used to meet MIPS reporting requirements beginning with the 2023 performance year. The MVP framework aims to align and connect measures and activities across the Quality, Cost, and Improvement Activities performance categories of MIPS for different specialties or conditions. In addition, MVPs incorporate a foundational layer that leverages Promoting Interoperability measures and a set of administrative claims-based quality measures that focus on population health/public health priorities. There are 7 MVPs that will be available for reporting in the 2023 performance year.
MIPS provides several data submission options, and most are available for Quality, Improvement Activities and the Promoting Interoperability performance categories. Data can be submitted via multiple mechanisms within a performance category. For example, a physician can utilize a registry to report some quality measures and claims to report others. If the same measure is submitted via multiple mechanisms, the one with the greatest number of measure achievement points will be selected for scoring.
Only small practices (≤15 eligible clinicians) can use Claims for data submission. It’s not an option if you’re participating in MIPS as a large group. Claims data is only available for the Quality performance category. If you choose to submit quality data through claims, Quality Data Codes (QDCs) will need to be added to denominator eligible claims to show that the required quality action occurred, or exclusion applied.
A Registry is a CMS-approved entity that collects clinical data from an individual MIPS-eligible clinician, group, and/or virtual group and submits the data to CMS on their behalf. Each registry is different; however, most will collect data for the Quality, Improvement Activities and Promoting Interoperability performance categories. A full list of CMS-approved entities can be found on the CMS website.
A Qualified Clinical Data Registry (QCDR) is a CMS-approved entity that collects clinical data from an individual MIPS-eligible clinician, group, and/or virtual group and submits the data to CMS on their behalf. The QCDR reporting option is different from a Registry because it is not limited to quality measures within MIPS. The QCDR can develop and submit QCDR measures for CMS consideration and approval.
An Electronic Health Record (EHR) can provide two ways to submit data to CMS. Either the vendor can submit MIPS data to CMS on your behalf or the vendor can provide the clinician with a Quality Reporting Document Architecture III (QRDA3) file which you can submit on your own through the CMS Portal.
The CMS Portal is a secure internet-based data submission mechanism available for all physicians and groups. To sign into the CMS portal, you will need your HCQIS Access Roles and Profile (HARP) system credentials and have the appropriate user role associated with your organization.