MIPS scores directly affect your Medicare reimbursement payments. According to the Centers for Medicare & Medicaid Services (CMS), Medicare's reimbursement rate is roughly 80% of the total bill. In 2024, physician reimbursement by Medicare is expected to decrease by 3%. It is estimated that 25.4% of all 258.3 million U.S. adults are enrolled in Medicare. That 3% can be a significant amount!

Planning and educating physicians about the consequences of non compliance with MIPS will be key to successfully reporting MIPS and putting your practice in the best position to offset the Medicare decrease in payments. CMS estimates that 54% of providers and groups will receive penalties in 2024! That will mean a further decrease beyond the 3% already projected.

While the focus of most practices seems to be MIPS reporting requirements, as it should be, there is one significant component that continues to be overlooked by clinicians. As an individual eligible clinician, your MIPS score follows the individual clinician. The payment adjustment it generates will follow the individual, MIPS eligible clinician, even if they change practices from one year to the next. Specifically, the MIPS score is tied to the NPI, not the TIN. Understanding this might make a significant difference in promoting clinician buy in for completeness in reporting!

For performance year 2024, the MIPS Extreme and Uncontrollable Circumstances (EUC) exemption is expected to twilight. If your practice is one of those that was granted the EUC exemption over the last few years, it is more important than ever that you develop and implement a plan to begin reporting MIPS on January 1, 2024. This will allow for the inevitable time it will take to modify workflows or enhance reporting to ensure completeness in the data collected and reported.

Another significant change to be aware of at the eligible clinician level is that, in the past, CMS has re-weighted the PI category for certain clinician types. For 2024, CMS will no longer automatically re-weight the PI category for the following clinicians: Physical therapists, Occupational therapists, Qualified speech-language pathologists, Clinical Psychologists, Registered dietitians or nutrition professionals. Some exceptions may be available but the direction of these changes is clear.

The proposed rule for 2024 includes an increase of the MIPS Performance Threshold from 75% to 82%. This means that the reporting group or individual must have a final MIPS score above 82% to participate in the incentive payments for 2026, which range from 0 to 9%. Less than 20.5% is a -9% Medicare payment adjustment in 2026 and from 20.51% to 81.99% will be a negative Medicare payment adjustment greater than 0 but less than 9%. Reimbursements will be determined on a sliding scale. Don’t be on the wrong side of the scale, Plan Ahead!

To illustrate the importance of planning for 2024, a proposed change to MIPS reporting in 2024 is to increase the Promoting Interoperability (PI) performance period to a minimum 180 continuous days from the current 90 day requirement. The PI category is responsible for 25% of your total score. If your practice is not prepared, they may not reach this threshold and will receive a 0 for the PI category. That will immediately put your practice in the negative payment adjustment category. It is that simple.