Has your practice performed for at least 90 days on Promoting Interoperability and Improvement Activities’ measures? If not, the clock is ticking! October 1 is the last chance to start a 90 continuous day count prior to the end of the year. Not paying attention to this 90 day window could cost the practice a 0 in one or more of the categories, making it nearly impossible to score the 75% needed to avoid the payment penalty zone.

Here is a short review on how the scoring works.

Each MIPS category, Quality, Promoting Interoperability (PI), Improvement Activities (IA) and Cost, is scored separately. The four component scores are added together for a total score as follows: Quality is 30 points, PI is 25 points, IA is 15 points and Cost is 30 points. Participants must achieve at least 75 points in order to avoid a negative payment adjustment (penalty). CMS determines the Cost value. The performance threshold is 75 points for performance year 2023.

Any practice that does not participate will incur a -9 percent penalty on their 2025 Part B Medicare payments. Those falling between zero and <75 points will face a penalty between 0 and -9%. Those scoring more than 75 points will receive a positive payment adjustment (bonus) between 0 and +9%. MIPS is a budget neutral program, which means the penalties must pay for the bonuses. There is no longer an exceptional performance bonus beginning in 2023 and moving forward.

There are still some exceptions, such as extreme and uncontrollable circumstances, (EUC) , and re-weighting of PI due to specific circumstances. Here is the link to check the eligibility of the practice for any special status or automatic exception. Eligibility Status.

MIPS Category Requirements Review:

Promoting Interoperability. 25 points unless re-weighted

All required measures must be reported (submit a “yes”/report at least one patient in the numerator, or claim an exclusion) or the practice will earn a zero for the Promoting Interoperability performance category. Incomplete data equals a 0!! Each practice:

• must use an Electronic Health Record (EHR) that meets the 2015 Edition Cures Update certification criteria
• must provide your EHR’s CMS identification code from the Certified Health IT Product List (CHPL)
• must submit data for the required measures in each objective for the same 90 continuous days during 2023.
• must submit a “Yes” to attest to the following: The Actions to Limit or Restrict Compatibility or Interoperability of CEHRT Attestation. The Office of the National Coordinator for Health Information Technology (ONC) Direct Review Attestation. The Security Risk Analysis Measure.
  The Safety Assurance Factors for EHR Resilience (SAFER) Guides Measure. Either submission will satisfy this attestation

Improvement Activities. 15 Points

Improvement activities have a minimum of a continuous 90-day performance period. Multiple activities don’t have to be performed during the same 90-day.

To receive full credit in the IA category, submit one of the following combinations of activities:

2 high-weighted activities,
1 high-weighted activity and 2 medium-weighted activities, or
4 medium-weighted activities.

Group and APM can attest to an activity when at least 50% of the clinicians in the group, virtual group, or APM perform the same activity during any continuous 90-day period in 2023.

Quality. 30 Points, if PI has been re-weighted, 55 points

The Quality category requires:

• data reporting for a full calendar year on, at least, 6 measures
• must include one outcome measure or high priority measure
• data for a minimum of t 70% of the eligible cases for each quality measure reported.
• data submitted for a minimum of 20 eligible cases.
• The CAHPS for MIPS Survey can be used as 1 of the 6 minimum required quality measures.

All of these categories are important to your practice Medicare reimbursements. Remember that any score below 75 total points is a potential for a negative adjustment to the reimbursements for the practice. For 2024 that required points will be 82. Don’t delay the inevitable. Position your practice to succeed. Quantician!

Cost. 30 Points

Cost is not manually submitted and is measured by CMS using claims data. There are 25 total cost measures available for the 2023 performance period. The practice has no control over the Cost category, making it even more important to earn the full amount possible from the other 3 categories.