The Quality Payment Program has undergone some major changes over the last several years and CMS has signaled that they intend to further modify the program in the years to come. It's hard to keep all the requirements straight. In this article, we will cover the major themes that came out of the recent final ruling, review the base requirements for all participants and then review the individual requirements according to a clinician's participation status.
There are three major themes to the changes CMS unfolded as a part of the 2024 PFS Proposed Rule.
Theme 1: MSSP ACOs must start reporting using eCQMs, CQMs, or Medicare CQMs. CMS did not extend the deadline for transitioning away from CMS Web Interface measures. That means by 2025, everyone must report Quality measures as either eCQMs, CQMs, or Medicare CQMs.
Also see: eCQM vs CQM vs Web Interface: Understanding the Difference
Theme 2: Subgroup reporting by specialty type is here. CMS expanded their reporting framework called MIPS Value Pathways (MVPs). MVPs include measures that are for specific specialty groups (like rheumatologists). CMS added five more MVPs, bringing the total to 16 different MVPs a group could use to report in 2024. Full sub-group reporting is optional until 2026, when it becomes mandatory (if you choose to report this framework).
Also see: The 2024 MVP Reporting Bundle
Theme 3: The end of Traditional MIPS is hovering like a specter above us. CMS didn't commit to it, but they haven’t officially backed off their statement that says they will retire the Traditional MIPS reporting framework at the end of 2027, which would mean everyone must report under the MVP reporting framework (subgroup reporting by specialty type required) or be involved with an APM Entity (such as an ACO) and report through the APM Performance Pathway (APP) framework.
Let’s dive into the details.
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CMS puts Eligible Clinicians into one or more categories.
To find out your participation framework, you must check your eligibility on the QPP website.
APM Entities will be referenced throughout.
The CMS participation statuses apply to the NPI associated with the provider. This eBook also references APM Entities. An APM Entity is responsible for reporting to this program on behalf of their participants.
Understanding the Frameworks
Once you know your participation status, you will understand which framework you can use for submission. There are three QPP frameworks in 2024:
This is the usual MIPS framework made up of four categories and a composite score.
The APP Framework is available to MIPS APM Entities and required for ACOs if they are part of MSSP.
The MVP framework focuses on sub-group reporting by specialty type – applicable specialty measures designed for specialists. This reporting framework will eventually replace Traditional MIPS.
Here is a matrix of which framework you can report to, based on your status.
Each framework has slightly different requirements and different category weights.
Collection types are the way you report the data to CMS. You can think of them like measures. There are six collection types in 2024.
As I mentioned before, CMS Web Interface is going away in 2025, so if this is the primary way you submitted your measures before, you need to figure out a new collection type soon.
Which collection type you can submit depends upon your participation status.
Now we are ready to review the requirements for each framework.
There are many opportunities to get bonus points within the MIPS program.
Clinicians will be rewarded if they demonstrate any improvement to their 2023 Quality score over the prior year (pending there is enough data for comparison). New Clinicians will be rewarded up to 1 additional point for improvement to their Cost performance scores.
For clinicians who work with patients that have more complex cases, CMS will award up to 5 points to account for the additional complexity of treating their patient population.
An additional 6 bonus points will be added to the numerator of the Quality category for anyone qualifying as a small practice.
Applicable to MIPS and MVP Reporting Frameworks
To avoid a -9% penalty, you must score at least 75 points.
If your score is between 0 and 18.75 points, you will lose -9% from your Medicare fee schedule (in red above).
If your score is between 18.76 and 74.99 points, you will receive a reduction to your Medicare fee schedule between -8.99% and 0%
75 points is the performance threshold. CMS will take the funds of those who did not meet the threshold (in red) and distribute them among those who did meet the threshold (in green). Anyone whose MIPS score is between 75 and 100 points will receive some portion of those funds – up to a 9% increase to your Medicare fee schedule.
Note: There is no longer an Exceptional Performance bonus
Shared Savings
To get the maximum shared savings for your ACO you must:
Report ALL measures in the APP measure set
AND
Achieve the Quality Performance Standard
CMS has implemented a sliding scale to give ACOs some percentage of the Shared Savings (not max) if they don’t meet the quality performance standards but do achieve a quality performance score equivalent to or higher than the 10th percentile of the performance benchmark on at least one of the four outcome measures.
Quality Performance Standard
OR
Health Equity-Adjusted score of => 40th percentile across ALL quality performance scores
CMS will calculate 2024 and 2025 benchmarks for the Medicare CQMs based on performance period benchmarks. They will transition to historical benchmarks in 2026 and subsequent years.
This means that ACOs will not know the Medicare CQM benchmarks during the performance period.
CMS is NOT extending the eCQM/MIPS CQM reporting incentive to Medicare CQMs.
CMS finalized the use of historical data to establish the 40th percentile MIPS Quality performance category score used for the quality performance standard.
That means you would know what the Quality Performance Standard percentile is BEFORE the performance year starts.
40th Percentile MIPS Quality Performance Category Scores Used in the Calculation of the PY 2024 Historical MIPS Quality Performance Category Score
| Performance Year | 40th Percentile of the MIPS Quality Performance Category Score |
| 2020 |
75.59^ |
| 2021 |
77.83^ |
| 2022 |
77.73^ |
| 2023 |
Skipped due to 1-year lag |
| 2024 |
77.05 |
^ PY 2020 through PY 2022 40th percentile scores are based on performance period data
The start date to track 365 days of Quality and Cost category measures.
Registration opens for CMS Web Interface, CAHPS for MIPS Survey, and MVP selection.
The last day to start measures in the Promoting Interoperability category to meet the minimum of 180 continuous days.
The last day to start Improvement Activities to meet the minimum requirement of 90 continuous days.
Last day to register for an MVP.
The last day to submit all of your performance data.
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