The final 2024 Medicare Physician Fee Schedule Rule will be out soon and there is little reason to believe it will be much different from the proposed rule, based on past years. Since the proposed rule is over 2000 pages long, here is a recap of just a few of the changes to consider when planning for 2024. Any one of the items mentioned below will have a significant impact on MIPS reporting and how it will affect practices and the amount of time and effort required to implement a successful MIPS plan.

To begin with, there is a 3.36% proposed cut to the 2024 Medicare physician payment Schedule conversion factor. Whether it is 3.6% or any other number, this proposed cut comes on the heels of the 2% cut in 2023. Add to that, CMS is projecting that the cost of inflation, measured by the Medicare Economic Index, is going to increase by 4.5% for 2024.

These payment reductions become more substantial when considering a 9% negative payment adjustment for failing to meet MIPS requirements. Conversely, MIPS scores become a significant tool for offsetting the proposed cuts when considering the potential of a +9% payment adjustment. The exceptions and automatic re-weighting options, previously available to many practices are dwindling. This makes it imperative for practices and physicians to create a successful MIPS program or fine tune their existing reporting procedures.

CMS has proposed to increase the performance threshold, the point at which a practice gets a positive or negative adjustment, from 75 points in 2023 to 82 points for the 2024 reporting year. Since there is a budget neutral mandate, the negative adjustments are calculated first and the positive adjustments will be determined on a linear sliding scale from 0 to 9% based on the funds collected from the negative adjustments. This maintains the mandated budget neutrality of the program.

For 2024, the data completeness scores are proposed to increase to 75% from the 70% required for 2023. Data completeness directly impacts which measures will be used to determine the scores for a practice. The 75% is proposed to stay in effect through 2026 and then go up to 80% in 2027.

Promoting Interoperability scores have required a 90 day continuous day minimum for each measure scored thus far. However, for 2024, the proposed rule will require 180 continuous days in 2024 and moving forward. There are only 5 clinician types left that will still have their PI scores automatically re-weighted in 2024: Physical therapists, Occupational therapists, Qualified speech-language pathologists, Clinical psychologist, Registered dietitians or nutrition professionals.

Many practices have been focussed on maintaining a neutral score. In 2024, the burden on most practices to maintain a score at a level that prevents a penalty will increase significantly. A score of 82 or above will only be possible through careful attention and focussed feedback and improvement. Securing the services of a MIPS expert/certified registry has become a business decision. The right help will add value and provide an excellent ROI for any practice.