New MIPS Proposed Changes: Make Your Voices Heard By September 11!

The Centers for Medicare and Medicaid Services (CMS) is requesting comments on the 2024 Quality Payment Program (QPP) Proposed Rule, and this is your opportunity to make your voice heard. 

At Anatomy IT, we're dedicated to championing the interests of our valued clients. As part of our commitment to excellence, we will be actively engaging in the comment submission process, sharing our insights and perspectives on the proposed rule. However, we recognize that a single voice can be more impactful when joined by many. This is why we extend an invitation to all stakeholders, including providers and practice administrators, to lend their voices to this pivotal conversation. 

The deadline for comment submission is Monday, Sept. 11, 2023 at 8 pm ET.

In this article, we will review the three biggest issues in the proposed rule: the performance threshold, the Cost category, and the Promoting Interoperability (PI) performance period increase. Your input matters! By collectively advocating for well-informed changes, we can shape a more effective and equitable 2024 QPP. 

Performance Threshold

CMS is proposing a performance threshold increase to 82 points to avoid a penalty for the 2024 performance year/2026 payment year. This change is a result of the proposed modification to the way MIPS performance thresholds will be calculated, where the average of performance means from three prior years will be used rather than the mean of the prior performance year. 

While this proposal would shield clinicians from dramatic annual shifts in the score required to avoid a penalty, the impact of COVID-19 on the years prior to the 2022 performance year make it difficult to compare with present times. The increased threshold also reflects years in which there were 12 more bonus points available in the Quality category and years in which few practices were scored on Cost.

This proposed change should be advocated against because it will negatively impact many practices that cannot reach such a high-performance threshold with the recent changes in MIPS.


Feedback Reports

The feedback reports our members have received from CMS have offered very little insight. It would be helpful to have more information beyond the Cataract Cost Measure score distributions and benchmark range cut-offs so that we can identify how and when services were attributed to clinicians and where the services occurred (ASC vs. HOPD). 

In order for us to determine how a practice can improve their Cost score, we need more information. It would also be useful to have the following included in Cost performance feedback:


The measure specification requires that an attributed provider has to prescribe at least two diabetes-related medications to different patients for clinicians reporting MIPS at the individual (TIN-NPI) level. 

It would be grossly inappropriate for a dermatologist or ophthalmologist to manage a patient’s diabetes, even if they treat a complication of the disease. Clinicians who do not treat or manage diabetes have no control over the total cost of diabetes care. Physicians should not be held accountable for the costs over which they have no control – especially when the specialist is only seeing diabetic patients who have already developed complications.

PI Performance Period Increase

CMS is proposing to increase the PI performance period from 90 consecutive days to 180 consecutive days. This is very difficult for many physicians to comply with due to issues that may occur outside their control such as system glitches or office relocations. 

Next Steps

The 2024 QPP Proposed Rule presents an opportunity for all of us to play a pivotal role in shaping the future of healthcare quality and ensuring that MIPS does not become more burdensome and detract from patient care. Here’s what you can do to make an impact:

  1. Comment on the proposed rule before September 11, 2023 at 8 pm ET
    1. Write up your take on the proposed changes that interest you most. This does not need to be lengthy, but make sure it’s in your own words.
    2. Submit your comments to CMS using this guide that we’ve developed. Once you’ve written your comments, it will take less than 5 minutes to submit them to CMS.
  2. For Anatomy IT clients scored on the 2022 Cataract Cost measure:
    1. Complete the survey we emailed you.
    2. The survey takes about 5 minutes to complete and will help us to provide more targeted feedback on how to improve your MIPS Cost score in future years.


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