As they do each year, CMS has made changes to the Quality Payment Program affecting MIPS, MVPs, and APMs and ACOs. Below is a synopsis of those changes. CMS provides a much more comprehensive guide for those requiring additional information in the Medicare Physician Fee Schedule Final Rule 2022.

Changes to 2023 Traditional MIPS

• There is no longer a bonus for exceptional performance in 2023.
• MIPS scores that are 18.75 or less will be penalized the full -9 percent.
• Data completeness for 2023 is now 75%, up from 70% in 2022.

QUALITY CATEGORY (30 points) UPDATES

The definition of “high priority measure” has been expanded to include health equity-related quality measures.

CMS will use performance period benchmarks exclusively for scoring administrative claims measures.

Policy changes:

• Measures with a benchmark -
  • The 3-point floor is removed
  • These measures will receive 1-10 points.*
• Measures without a benchmark -
  • The 3-point floor is removed except for small practices
  • These measures will receive 0 points*
• Measures that don’t meet case minimum requirements (20 cases) -
  • The 3-point floor is removed except small practices.

*This does not apply to new measures in the first 2 performance periods available for reporting or to administrative claims measures. Measures calculated from administrative claims are excluded from scoring if the case minimum is not met.

New Quality Measures

• #485 Psoriasis – Improvement in Patient-Reported Itch Severity
• #486 Dermatitis – Improvement in Patient-Reported Itch Severity
• #487 Screening for Social Drivers of Health
• #488 Kidney Health Evaluation
• #489 Adult Kidney Disease: Angiotensin Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy
• #490 Appropriate Intervention of Immune-Related Diarrhea and/or Colitis in Patients Treated with Immune Checkpoint Inhibitors
• #491 Mismatch Repair (MMR) or Microsatellite Instability (MSI) Biomarker Testing Status in Colorectal Carcinoma, Endometrial, Gastroesophageal, or Small Bowel Carcinoma
• #492 Risk-Standardized Acute Cardiovascular-Related Hospital Admission Rates for Patients with Heart Failure under the Merit-based Incentive Payment System
• #493 Adult Immunization Status

Quality Measures Removed

• #76 Prevention of Central Venous Catheter (CVC) - Related Bloodstream Infections
• #119 Diabetes: Medical Attention for Nephropathy
• #258 Rate of Open Repair of Small or Moderate Non-Ruptured Infrarenal Abdominal Aortic Aneurysms (AAA) without Major Complications (Discharged to Home by Post-Operative Day #7)
• #265 Biopsy Follow-Up
• #323 Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Routine Testing After Percutaneous Coronary Intervention (PCI)
• #375 Functional Status Assessment for Total Knee Replacement
• #425 Photodocumentation of Cecal Intubation
• #455 Percentage of Patients Who Died from Cancer Admitted to the Intensive Care Unit (ICU) in the Last 30 Days of Life (lower score – better)
• #460 Back Pain After Lumbar Fusion
• #469 Functional Status After Lumbar Fusion
• #473 Leg Pain After Lumbar Fusion
• #110: Preventive Care and Screening: Influenza Immunization*
• #111: Pneumococcal Vaccination Status for Older Adult * - When reporting under traditional MIPS, a new Adult Immunization Status measure will include influenza and pneumococcal vaccination, as well as Td/Tdap and Zoster vaccination.

*These quality measures have been removed from Traditional MIPS but will still be available for MVP reporting. Measure #110 will also be available for MSSP ACO reporting through the APP.

IMPROVEMENT ACTIVITIES (15 POINTS) UPDATES

New Improvement Activities

• IA_AHE_10 Adopt Certified Health Information Technology for Security Tags for Electronic Health Record Data (Medium)
• IA_AHE_11 Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients (High)
• IA_EPA_6 Create and Implement a Language Access Plan (High)
• IA_ERP_6 COVID-19 Vaccine Achievement for Practice Staff (Medium)

Improvement Activities Removed

• A_BE_7 Participation in a QCDR, that promotes use of patient engagement tools

• IA_BE_8 Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive

• IA_PM_7 Use of QCDR for feedback reports that incorporate population health

• IA_PSPA_6 Consultation of the Prescription Drug Monitoring program

• IA_PSPA_20 Leadership engagement in regular guidance and demonstrated commitment for implementing practice improvement changes

• IA_PSPA_30 PCI Bleeding Campaign

PROMOTING INTEROPERABILITY CATEGORY (25 POINTS) UPDATES

New in PI:

• Electronic Prescribing Objective’s Query of Prescription Drug Monitoring Program (PDMP) measure is now required and has been modified.
• Query of PDMP measure now includes Schedule II opioids and Schedule III, and IV drugs.
• HIE Objective option: Enabling Exchange under the Trusted Exchange Framework and Common Agreement (TEFCA) measure, as an optional alternative to fulfill the objective.
• Consolidating the current options from three to two levels of active engagement for the Public Health and Clinical Data Exchange Objective
  • requirement to report active engagement for the measures under the objective.

Removed in PI:

• Automatic reweighting for the following clinician types beginning in 2023.
  • Nurse practitioners
  • Physician assistants
  • Certified registered nurse anesthetists
  • Clinical nurse specialist

Note: When participating in MIPS as an APM Entity, CMS will now allow APM Entities to report PI data at the APM Entity level or they can still report at the individual and group levels.

Updated PI scoring for the following measures:

• Electronic Prescribing
  • e-Prescribing 10 points
  • Query of PDMP 10 points
• Health Information Exchange
  • Support Electronic Referral Loops by Sending Health Information 15 points
  • Support Electronic Referral Loops by Receiving and Reconciling Health Information 15 points OR
  • Health Information Exchange Bi-Directional Exchange 30 points OR
  • Participation in TEFCA 30 points
• Provider to Patient Exchange
  • Provide Patients Electronic Access to Their Health Information 25 points
• Public Health and Clinical Data Exchange
  • Report the following 2 measures: 25 points
    • Immunization Registry Reporting
    • Electronic Case Reporting
  • Report one of the following measures: 5 points (bonus)
    • Syndromic Surveillance Reporting
    • Public Health Registry Reporting
    • Clinical Data Registry Reporting

Cost Category (30 POINTS) Updates

A maximum cost improvement score of one percentage point out of 100 percentage points is established for the Cost performance category. It will be retroactively applied to start with the current 2022 performance period.

Complex Patient Bonus

CMS finalized that a facility-based MIPS eligible clinician will still be eligible to receive the bonus, even if they fail to submit data for one of the MIPS performance categories.

MIPS Value Pathways (MVPs)

Now available for reporting for the following groups:

• APM Entities
• Individual clinicians
• Multi-specialty groups (2023-2025)
• Single specialty groups
• Subgroups
  • Clinicians can only register for one subgroup per TIN
  • Registration open from 04/01/23 - 11/30/23
  • One eligible clinician per group required
  • Administrative claims measures will be scored at the TIN level

MVPs available for 2023:

• Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP
• Improving Care for Lower Extremity Joint Repair MVP
• Advancing Cancer Care MVP
• Optimal Care for Kidney Health MVP
• Advancing Care Heart Disease MVP
• Optimizing Chronic Disease Management MVP
• Advancing Rheumatology Patient Care MVP
• Patient Safety and Support of Positive Experiences with Anesthesia MVP
• Optimal Care for Patients with Episodic Neurological Conditions MVP
• Promoting Wellness MVP
• Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes MVP
• Supportive Care for Neurodegenerative Conditions MVP

Advanced APMs

• Generally applicable nominal amount standard is 8% minimum.
• Medical Home Model will have the 50 clinician limit applied as identified by CMS
• using the TIN/NPI as submitted by the APM Entity on any of the three QP determination dates (March 31, June 30, and August 31).