Medicare Compliance & Reimbursement

Pocket 7 top QPP and MSSP policies for next year.

The 2023 rulemaking cycle was a banner year for Medicare’s quality and cost initiatives. So, it shouldn’t come as a surprise that the agency opted to refine programs and policies instead of another overhaul. Read on for the scoop.

Refresher: The Centers for Medicare & Medicaid Services (CMS) rolled out some major updates to the Medicare Shared Savings Program (MSSP) in the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) final rule, after claiming that the quality-and-cost-focused program had plateaued. During performance year (PY) 2023, the agency also began its slow implementation of the specialty-centered Merit-Based Incentive Payment System (MIPS) Value Pathways program, which is slated to replace traditional MIPS in the years ahead.

Now: On Nov. 16, CMS published the CY 2024 MPFS final rule in the Federal Register, and as usual, the updates to Medicare fee-for-service reimbursement are extensive. However for 2024, CMS chose not to reinvent the wheel for its quality programs, instead fine-tuning MSSP policies finalized in 2023 and making limited adjustments to the Quality Payment Program (QPP).

Additionally, CMS’ policies for the MSSP and QPP tie in with other initiatives across the various programs to promote and support equity, primary care, and value.

“CMS remains steadfast in our commitment to supporting physicians and ensuring that people with Medicare have access to the care they need to stay healthy as well as navigate health conditions they are facing,” says CMS Administrator Chiquita Brooks-LaSure in a release.

Factor in These 7 Takeaways

During the COVID-19 public health emergency (PHE), CMS introduced several initiatives to improve beneficiaries’ healthcare experiences and promote coordinated care. The CY 2024 MPFS final rule reflects that as the agency continues to connect reimbursement and quality programs with initiatives that support “whole-person care” like the Behavioral Health Strategy, National Quality Strategy, and the HHS Initiative to Strengthen Primary Care.

For example, “one of the CMS National Quality Strategy goals is to improve quality and health outcomes across the health care journey through implementation of a ‘Universal Foundation’ of impactful measures across all CMS quality and value-based programs,” the final rule explains.

Take a look at seven MSSP and QPP updates to know for CY 2024:

1. Prepare for CEHRT alignment between MIPS and the MSSP … in 2025. To better allow Accountable Care Organizations (ACOs), ACO providers/suppliers, and ACO professionals time to gear up for the new requirement, CMS finalized but delayed the implementation. Starting Jan. 1, 2025, ACO participants that are also MIPS participants — no matter the track —will be “required to report the MIPS Promoting Interoperability performance category measures and requirements to MIPS and earn a performance category score for the MIPS Promoting Interoperability performance category at the individual, group, virtual group, or APM Entity level,” CMS says.

CEHRT public reporting for ACOs also got pushed back to 2025.

2. Understand the new collection type for ACOs in the APP — Medicare CQMs. Starting with the 2024 performance year, CMS is instituting a new collection route that harnesses MIPS methodologies, but that is for ACOs participating in the MSSP under the Alternative Payment Model (APM) Performance Pathway (APP). The Medicare Clinical Quality Measures (CQMs) aim to use data aggregation that supports population-health initiatives and aligns with the “Universal Foundation,” which is quality measurement across a person’s life.

“Standards for data completeness, benchmarking, and scoring ACOs for the Medicare CQM collection type will align with MIPS benchmarking and scoring policies,” CMS says in a fact sheet.

3. Review all the MSSP benchmarking and methodology modifications. For CY 2024, CMS is tweaking its policy revamps from last year. As is typically the case, revisions are extensive and include the following, according to CMS guidance:

• Modifying how the regional component of the three-way blended benchmark update factor is calculated;
• Capping Hierarchical Condition Category (HCC) regional risk score growth;
• “Apply[ing] the same CMS-HCC risk adjustment model used in the performance year for all benchmark years, when calculating prospective HCC risk scores to risk adjust expenditures used to establish, adjust, and update an ACO’s benchmark;”
• Nixing negative regional benchmark adjustments to incentive ACOs to take on beneficiaries with complex medical issues; and
• Amending the beneficiary assignment methodology.

4. Know these top category changes. For PY 2024, CMS kept the same number of Quality measures, 198; however, it did this by removing 11 and then adding 11 new ones. Additionally, the agency made “substantive” changes to 59 of the measures.

For the Improvement Activities (IA) category, CMS added five new measures, changed one, and deleted three for a total of 106 measures for CY 2024. Meanwhile under the Promoting Interoperability (PI) category, the performance period will now be 180 continuous days, instead of 90.

CMS finalized the Cost improvement scoring methodology, and it will be applied to the beginning with the 2023 performance period/2025 payment year. “Improvement will be measured at the category level, rather than the measure level,” CMS says.

5. See the ICD-10-CM coding updates under the Quality performance category. CMS changed three things on how it uses ICD-10 codes for Quality measurement. CMS will no longer use the “10 percent threshold of coding changes that triggers measure suppression or truncation,” the 2024 QPP fact sheet on the final rule says. The agency will also assess how ICD-10 coding changes affect Quality measures on a “case-by-case basis” as well as separately evaluating the connection between collection types and ICD-10 codes, the fact sheet indicates.

6. Expect more connectedness with the “Universal Foundation” ideology. Just like with the MSSP, CMS plans to weave the “Universal Foundation” strategy through its QPP policies. “Adoption of the Universal Foundation will focus clinician attention on specific quality measures, reduce burden, help identify disparities in care, prioritize development of interoperable, digital quality measures, allow for cross-comparisons across programs, and help identify measurement gaps,” the rule notes.