Navigate the latest MIPS and QPP Proposed Rule: A Comprehensive Overview for CY 2024

The Centers for Medicare and Medicaid Services (CMS) has officially released the 2024 Quality Payment Program (QPP) proposed rule. The 1,920-page proposed rule contained many changes that may take place in the 2024 MIPS performance year and beyond.

This blog post breaks down the proposed changes to the QPP and MIPS for 2024.

 

Performance Threshold

CMS is proposing to significantly increase the threshold to avoid a penalty from 75 points in 2023 to 82 points for 2024. 

 

Category Weights

CMS is not proposing changes to performance category weights in 2024.

MIPS Performance Categories

 

Quality Category

Measure Scoring

No proposed changes, so the following measure scoring rules will remain in effect:

  • For large practices (>15 clinicians), remove the 3-point floor for measures meeting data completeness and case minimum. These measures would be scored on a 1-10 point scale instead of a 3-10 point scale.
  • For small practices, the 3-point floor will remain.


Bonuses 

  • No change to the small practice bonus or the improvement score bonus.

Measures 

Three new ophthalmology-specific measures are being proposed in this year’s rule:

  • Appropriate Screening and Plan of Care for Elevated IOP Following Intravitreal or Periocular Steroid Therapy
  • Acute Posterior Vitreous Detachment Appropriate Examination and Follow-up
  • Acute Posterior Vitreous Detachment and Acute Vitreous Hemorrhage Appropriate Examination and Follow-up

We had the opportunity to test these measures with the ASRS last year, and we are excited to implement them for our retina specialists in 2024.

Overall, CMS is proposing to remove 12 MIPS quality measures, modify 59 existing measures, and add 14 new quality measures. For pertinent measure changes, review our Top 2024 Proposed MIPS Changes Report.


Data Completeness Threshold 

  • Increasing to 75% in 2024 (up from 70% in 2023).
  • In 2027: proposal to increase to 80%.

Cost Category

Scoring

CMS proposes to change the calculation of the Cost category improvement score* from being measure-based (meaning that only measure-specific improvement would receive a Cost category bonus) to being calculated at the category-level (meaning that overall category score improvement would lead to a Cost category improvement bonus). 

*The Cost improvement score bonus will remain limited to a maximum of 1 percentage point added onto the category performance percent.

Measures

There are no proposed changes to the cataract measure, the melanoma measure, or the diabetes measure.

CMS is proposing to add five new episode-based cost measures:

  • Depression
  • Emergency Medicine
  • Heart Failure
  • Low Back Pain
  • Psychoses and Related Conditions

CMS also proposes to remove the Simple Pneumonia with Hospitalization measure as they are no longer able to assess the cost of pneumonia-related care due to coding changes.

Improvement Activities

CMS proposed no significant changes for scoring or reporting this category. There are several proposed changes to the list of improvement activities (IAs), including:

  • Five proposed new IAs, none of which are relevant to our specialists.
  • One change proposed to an existing IA (IA_PSPA_16: Use of Decision Support and Standardized Treatment Protocols). 
  • Three proposed removals, none of which are relevant to our specialists.

Promoting Interoperability (PI)

CMS proposed to increase the performance period to 180 consecutive days (up from 90 consecutive days in 2023) to align with the performance period in the Promoting Interoperability Program for eligible hospitals.

CMS is proposing the following measure changes beginning in 2024:

  • Query of Prescription Drug Monitoring Measure: Change to low-volume exclusion
    • Current language: “Eligible clinician writes fewer than 100 permissible prescriptions during the 90-day performance period”.
      • For the purposes of this exclusion, “permissible prescriptions” refers to Schedule II opioids and Schedule III and IV drugs.
    • Proposed language: “Does not electronically prescribe any Schedule II opioids or Schedule III or IV drugs during the performance period.”
    • This change explicitly excludes only clinicians or groups that do not e-prescribe any Schedule II opioids and Schedule III and IV drugs.
  • Safety Assurance Factors for EHR Resilience (SAFER) Guides Measure
    • CMS proposes to require a “yes” response for this measure beginning with the 2024 performance year.
    • For more information on the SAFER Guides, review our Guide to the SAFER Guide.

 

MIPS Value Pathways (MVPs)

There are no currently available or proposed MVPs relevant to our specialists.

 

Next Steps

  • Review our Top 2024 Proposed MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.
  • Subscribe to our newsletter to get alerts on this and other important issues.
  • If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

 


Jessica Peterson, MD, MPHWritten By: Jessica Peterson, MD, MPH

About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.