Changes to MIPS for 2024: What You Need to Know

MIPS 2024 Updates

Healthcare providers grapple with the dual challenge of managing bustling clinics and keeping pace with ever-changing regulatory requirements. The complexity intensifies with the demands of the Merit-based Incentive Payment System (MIPS), requiring providers to deliver top-notch care and navigate the intricate data collection and reporting process. Only adding to the complexity are updates to the MIPS program that may change eligibility. Read on to learn how to leverage the MIPS 2024 updates to achieve compliance and improve efficiencies in your practice.

What is MIPS, and How Does It Work?

MIPS is pivotal in determining how much a practice will receive in Medicare payment adjustments for a given performance period. 

Eligible clinicians (ECs) receive a composite performance score that determines whether they will receive a payment bonus, a penalty, or no payment adjustment. 

The final MIPS score, based on four categories—Quality, Improvement Activities, Promoting Interoperability, and Cost—determines the payment adjustment for Medicare Part B claims. 

By aligning with these performance measures, healthcare providers can meet regulatory standards, enhance their practice’s overall efficiency and effectiveness, and maximize their ROI.

Why MIPS Matters

The MIPS program is required for Medicare Part B eligible clinicians. Failure to participate can result in a negative 9% payment adjustment in their Medicare payment Part B reimbursements.  

Penalties may be imposed by more government regulations or other providers. 

MIPS scores are published on physician compare websites, meaning they may also play a significant role in patient decision-making. 

As a dynamic catalyst, MIPS propels the healthcare industry towards a culture of continuous improvement, motivating providers to elevate the standard of care they consistently offer patients.

MIPS 2024 Updates

2024 ushers in a series of pivotal updates, shaping the landscape of performance-based reimbursement with modifications spanning Quality, Promoting Interoperability, Improvement Activities, Cost, and specific changes tailored to ophthalmology, along with refinements to the APM Performance Pathway (APP) Reporting.

Before exploring specific changes, it is worth noting that the penalty threshold will remain at 75 and the 2024 final rule does not indicate any changes to the way scores will be measured or how points are achieved.

Quality Modifications

Expect MIPS 2024 updates to bring nuanced adjustments, focusing on critical aspects such as outcomes, patient experience, and the efficient use of resources.

The reporting period for the quality category remains at 12 months but the data completeness threshold has increased from 70% to 75%. This means that ECs must report 75% of eligible instances for the year if they wish to maintain compliance and receive maximum points for each quality measure. 

Be aware that a proposed rule change would see an increase of the data completeness threshold to 80% for the years 2026 and 2027.   

In 2024, there are 198 quality measures available with 13 new additions. 11 quality measures were removed and 59 were modified.

Of the new quality measures, 3 of them are specific to ophthalmology. 

Ophthalmology Quality Measure Changes

MIPS 2024 updates to quality measures for ophthalmology and optometry include the following:

Quality Measure Additions

  • Connection to Community Service Provider
  • Appropriate Screening and Plan of Care for Elevated Intraocular Pressure Following Intravitreal or Periocular Steroid Therapy
  • Acute Posterior Vitreous Detachment Appropriate Examination and Follow-up
  • Acute Posterior Vitreous Detachment and Acute Vitreous Hemorrhage Appropriate Examination and Followup

 

Quality Measures Finalized for Removal

  • Age-Related Macular Degeneration (AMD): Dilated Macular Examination

 

Significant Changes to the Following Measures

  • Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care
  • Primary Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 15% OR Documentation of a Plan of Care
  • Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery

Promoting Interoperability Modifications

Interoperability remains at the forefront of healthcare transformation. MIPS 2024 updates bring crucial modifications to the Promoting Interoperability category

For 2024, the promoting interoperability reporting period has been increased to 180 consecutive days, up from the previous benchmark of 90 consecutive days. 

The updates also lay out a new Query of the Prescription Drug Monitoring Program Measure exclusion for providers who e-prescribe fewer than 100 Schedule II-IV medications. 

The Safety Assurance Factors for EHR Resilience (SAFER) Guides Measure now requires a “yes” response to satisfy the SAFER Guide measure.

Automatic reweighting is discontinued for 2024 for the following types of clinicians:

  • Physical therapists
  • Occupational therapists
  • Qualified speech-language pathologists
  • Clinical psychologists
  • Registered dietitians or nutrition professionals

Automatic reweighting will continue for: 

  • Clinical social workers
  • ASC-based clinicians and groups
  • Hospital-based clinicians and groups
  • Non-patient facing clinicians and groups
  • Clinicians in a small practice
Changes to the Use of CEHRT by APMs for 2025

Beginning in 2025, Advanced Alternative Payment Models (APMs) must require the use of Certified Electronic Health Record Technology (CEHRT).

EHR technology must be certified under the ONC Health IT Certification Program and meet the following requirements: 

  • Meet the 2015 Edition Base EHR definition or any subsequent Base EHR definition.
  • Meet any ONC health IT certification criteria that are determined applicable for the APM.

Improvement Activities Modifications

For 2024, MIPS revamped the Improvement Activities category.

The reporting period for this category remains at 90 consecutive days and the final rule introduces 5 new improvement activities and removes 3. 

Additions to the Improvement Activities Category are:

  • Improving Practice Capacity for Human Immunodeficiency Virus (HIV) Prevention Services Guidelines (submitted by CDC)
  • Practice-Wide Quality Improvement in MIPS Value Pathways]
  • Use of Decision Support to Improve Adherence to Cervical Cancer Screening and Management
  • Behavioral/Mental Health and Substance Use Screening & Referral for Pregnant and Postpartum Women
  • Behavioral/Mental Health and Substance Use Screening & Referral for Older Adults

The activities removed are: 

  • Implementation of co-location PCP and MH services
  • Obtain or Renew an Approved Waiver for Provision of Buprenorphine as Medication-Assisted Treatment [MAT] for Opioid Use Disorder
  • Consulting Appropriate Use Criteria (AUC) Using Clinical Decision Support when Ordering Advanced Diagnostic Imaging

Data validation files will require review to ensure that ECs are properly documenting the completion of the chosen activities that they have attested to being completed.

Cost Modifications

2024 sees very few MIPS Scoring Changes concerning the Cost Category. 

There are, however, 5 new episode-based cost measures for the 2024 performance period. 

The new measures are:

  • Depression (chronic condition) 
  • Emergency Medicine (care provided in an emergency department setting)
  • Heart Failure (chronic condition)
  • Low Back Pain (chronic condition)
  • Psychoses and Related Conditions (acute inpatient medical condition)

Due to coding changes, the Simple Pneumonia with Hospitalization acute inpatient medical condition measure has been removed. 

Changes to APM Performance Pathway (APP) Reporting

Many of the changes to MIPS Reporting Requirements can be found in the APM Performance Pathway.

MIPS 2024 Updates

To begin, 2024 will be the final year to use the Centers for Medicare and Medicaid Services (CMS) Web Interface as a collection type for the Shared Savings Program ACOs reporting quality measures. Starting in 2025, Accountable Care Organizations (ACOs) must report electronic Clinical Quality Measures (eCQMs), MIPS CQMs, and/or the new Medicare CQMs.

Medicare CQMs is a collection type that has been created specifically for ACOs and can only be reported under the APP. These quality measures will address the data aggregation and patient matching issues experienced by Shared Savings Program ACOs when reporting eCQMs and MIPS CQMs.

For this collection type, participating ACOs in the Shared Savings Program must collect and report data on ACO’s Medicare fee-for-service beneficiaries alone and not all-payer/all-patient populations.

The CMS will share a list of patients eligible for Medicare CQMs with ACOs each quarter. These lists will include beneficiary-level information to support ACOs in identifying the eligible population for each measure.

The goal of these changes is to reduce the reporting burden of ACOs and help them capture all eligible beneficiaries, allowing them to prepare submission data in advance. 

Note that ACOs will still be responsible for assessing their patient population against each Medicare CQM Specification and ensuring all data accuracy. Multiple data sources can be used, including paper records, registries, patient management systems, and electronic health records (EHRs). 

Master MIPS Reporting with Harris CareTracker

Managing MIPS reporting requirements can be made easier with the right technology. 

Harris CareTracker offers comprehensive EHR and Practice Management solutions that simplify interoperability, data management, and data aggregation. 

CareTracker can not only improve patient experience and quality of care, but it can ensure you meet all MIPS requirements. We also offer MIPS consultation assistance ensuring that you meet compliance and optimize reimbursements.

For further information or to book a consultation, contact Harris CareTracker.

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