With the 2024 Final Rule, we have seen many changes and additions to MIPS for the 2024 performance year that are critical to take note of. The Merit-Based Incentive Payment System (MIPS) is a Medicare payment adjustment program that determines how much you or your practice will be paid in Medicare payment adjustments. This adjustment can range from negative 9% to positive 9% and is determined by an evaluation of your composite performance score. A score composed of Quality, Promoting Interoperability (PI), Improvement Activities, and Cost measures with their respective weights as shown below.

This is critical because Medicare Part B Eligible Clinicians (EC’s) are required to partake in the MIPS Program or face a negative 9% payment adjustment penalty. With that said, it is important to take note of the MIPS Program changes occurring for the 2024 performance year.

Overall Change The greatest change the program saw was the 2024 Final Rule decision to keep the penalty adjustment threshold at 75 - a relief for many Eligible Clinicians who expected an increase.

Changes to Quality Measures In 2024, the Quality reporting period will remain unchanged (12 months) with the requirement that 6 quality measures and one high-priority measure is still reported. The first change to come from the Final Rule is the completeness threshold that was increased from 70% to 75%, indicating that to be compliant and receive the maximum points for each quality measure, you must report at least 75% of all eligible instances for the reporting year. This is not the only change affecting quality measures.

In 2024, 11 new quality measures were added, 11 measures were removed, and 3 measures were removed from traditional MIPS but remain for MVP reporting for a total of 198 quality measures available for reporting.

Changes to Promoting Interoperability Measures In 2023, the PI category reporting period was known to be 90 consecutive days, however, in 2024 it will increase to 180 consecutive days. It continues to be noted that EC’s must meet the Electronic Health Record (EHR) Cures Act requirements to be able to report for this category. The Certified Electronic Health Record Technology (CEHRT) definition has been updated to shift from references to the “2015 Edition health IT certification criteria” and will instead reference “ONC health IT certification criteria”.

The PI category also underwent changes regarding automatic reweighting. According to the 2024 Final Rule, CMS made the decision to discontinue automatic reweighting for some clinician types, while continuing for others. Use the table below to determine which clinician types will be affected and which will remain unchanged.

The PI Measure changes include two new updates from the Final Rule. The first is that CMS modified the Query of Prescription Drug Monitoring Program (PDMP) exclusion to now accommodate EC’s who do not e-prescribe any Schedule II-IV medications throughout the performance period.

Lastly, beginning with the 2024 performance period, a “yes” response is required for the Safety Assurance Factors for EHR Resilience (SAFER) Guides Measure.

Changes to Improvement Activities Measures Unlike the PI category reporting period, the period for Improvement Activities Measures remains 90 consecutive days for 2024. The key changes within this category fall within the 5 new improvement activities and the 3 that were removed as shown below. This adds to 106 total Improvement Activity options.

Changes to Cost Measures For Cost Measures, there are no great changes from the 2024 Final Rule. Although it is important to understand that there are 5 new episode-based Cost Measures, creating a total of 29 cost measures available for calculating a cost score.

MIPS Value Pathways (MVPs) According to the 2024 Final Rule, there are 16 MVPs available, including 5 new MVPs for the 2024 performance year shown below.

Changes to APM Performance Pathway (APP) Reporting The 2024 performance year will be the final performance year that the CMS Web Interface will be an available collection type as 2025 will be the year ACOs must begin reporting to either eCQMs, CQMs, and/or Medicare CQMs.

Medicare CQMs is a newly created collection type for ACOs and can only be reported under the APP. The Medicare CQMs were specifically designed to address the struggles Shared Savings ACOs were facing when reporting to eCQMs and MIPS CQMs under the APP. For this collection type, an ACO that participates in the Shared Savings Program is required to collect and report data only on the ACO’s Medicare fee-for-service beneficiaries. On a quarterly basis, CMS will share a list of eligible patients that will include encounters from specific time periods and be updated quarterly according to the following:

What to Do Next CMS, under the 2024 Final Rule, has made significant changes to the Quality Payment Program. These changes affect the traditional MIPS Program, APM, MVP, and ACO reporting for the 2024 performance year. Begin to adapt and deepen your understanding by reviewing each of these changes now to take proactive steps in preparing for their potential impact on you and your practice’s 2024 reporting activities. To streamline, automate, and maximize your performance, consider working with a CMS Qualified Registry, like Quantician, to best ensure compliance for 2024.