Practice Management Alert

Breathe a bit more freely with CMS’ acknowledgment of COVID’s impact on providers.

The Centers for Medicare & Medicaid Services (CMS) has provided an update on the Merit-Based Incentive Payment System (MIPS), acknowledging the impact COVID has had on healthcare by shifting to a softer launch of its MIPS Value Pathways (MVPs) program.

CMS released more information via a Quality Payment Program (QPP) proposed rule, published in the Federal Register July 29. Here’s what you need to know.

Beware These Adjustments

Medicare providers have been hit hard these last few years, and CMS acknowledges that fact, offering more nuanced policies that decrease burdens. “We recognize the challenges faced by many across the country over the past two years,” CMS says in a QPP CY 2023 fact sheet on the proposed rule. We “remain committed to promoting more meaningful participation for clinicians and ensuring our policies continue to drive us toward value and improved health outcomes for patients,” the agency maintains.

Here’s a breakdown of the key proposals:

Traditional MIPS: CMS aims to offer MIPS-eligible clinicians (ECs) “continuity and consistency while they gain familiarity with MVPs,” the fact sheet indicates. The agency’s proposals include the following:

• CMS wants to use 2017 performance year/2019 payment year data to determine 2023 performance year/2025 payment year thresholds and set the threshold at 75 points, reminding that the 2022 performance year was the final year for the additional exceptional performance adjustment. The agency expects this policy decision “would subject approximately one-third of MIPS eligible clinicians to negative payment adjustments for the CY 2023 performance period,” explains Suzanne Michelle Joy, senior public affairs advisor with law firm Holland & Knight LLP, in online analysis.
• CMS proposes several equity-inspired updates, including redefining what high-priority measure means; cutting quality measures from 200 to 194; updating QPP standards with equity language; and adding, revising, or deleting specific improvement activities.
• As has been the case in past rules, CMS proposes several changes to the Promoting Interoperability updates. First, the agency advises making the Query of Prescription Drug Monitoring Program (PDMP) measure a required measure. CMS also proposes offering a third option to fulfill the Health Information Exchange (HIE) objective by participating in the Trusted Exchange Framework and Common Agreement (TEFCA) and updating the clinician types on the automatic reweighting list.

MVPs: As a reminder, MVPs focus more on specialty and scope, offering ECs the option to report “a more connected, cohesive set of measures and activities and allowing for comparative feedback that will be more beneficial to patients,” the fact sheet notes. For CY 2023, CMS proposes modifying the seven MVPs it has already established, according to the rule. Those include revisions to the following MVPs:

1. Advancing Care for Heart Disease
2. Optimizing Chronic Disease Management
3. Advancing Rheumatology Patient Care
4. Improving Care for Lower Extremity Joint Repair
5. Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
6. Patient Safety and Support of Positive Experiences with Anesthesia
7. Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes

Plus, CMS intends to add five more MVPs for the 2023 performance year. The proposed rule mentions these MVP additions: Advancing Cancer Care; Optimal Care for Kidney Health; Optimal Care for Neurological Conditions; Supportive Care for Cognitive-Based Neurological Conditions; and Promoting Wellness.

CMS also offers more guidance on MVP subgroup eligibility, registration, and scoring, the rule says.

Advanced APMs: In its CY 2023 proposals, CMS aims to bolster participation in the higher QPP track, Advanced Alternative Payment Models (AAPMs).

Remember, AAPMs offer differentiated services to patients, but they come with a plethora of financial rewards for providers — as well as risks. Originally, the current Generally Applicable Nominal Risk standard, which is set at 8 percent, was slated to expire in performance year 2024 and increase. Instead, CMS proposes to make the 8 percent minimum permanent. “This standard determines which models have sufficient risk to qualify as an AAPMs and would not impact individual AAPM Entities,” Joy explains.

Plus, Know About 2021 Targeted Reviews

If your MIPS data, final score, or payment adjustment for the 2021 performance year doesn’t match up with your files, now is the time to request a targeted review before the window closes.

Then: CMS recently updated EC accounts with 2021 performance year final scores for preview. The preview option is new this year and is part of CMS’ efforts to offer providers more transparency about payment adjustments and MIPS final scores.

Remember: “For MIPS-eligible clinicians, your 2021 final score determines the payment adjustment you’ll receive in 2023; a positive, negative, or neutral payment adjustment will be applied to the Medicare paid amount for covered professional services furnished in 2023,” reminds CMS in an Aug. 22 alert.