What You Need to Know for the Quality Payment Program in 2024

Quality Payment Program

Preparing your 2024 reporting strategy involves understanding the Merit-Based Incentive Payment System (MIPS) and the ongoing changes for clinicians.

Review the following updates for your 2024 reporting year to ensure you get paid for your Medicaid services.

Quality Payment Program: Key Updates in 2024

The MIPS Quality Payment Program (QPP) gives Medicare physicians and clinicians a chance to be paid more for providing better care. There are two ways to take part in this program: 

  • Merit-based Incentive Payment System (MIPS)
  • Advanced Alternative Payment Models (APMs) 

Under MIPS, eligible clinicians’ repayment by Medicare is affected by four pillars or categories: 

  1. Quality, 
  2. Clinical Practice Improvement Activities (referred to as “Improvement Activities”), 
  3. Certified EHR Technology (referred to as “Advancing Care Information”), and 
  4. Resource Use (referred to as “Cost”).

At its core, the Quality Payment Program is about improving the quality of care. In determining a total score, specific weights are assigned to each of the four performance categories.

The Centers for Medicare and Medicaid (CMS) with Health and Human Services published the 2023 Merit-Based Payment System Final Rule.

After five years, the special COVID hardship waiver has ended. In 2024, MIPS will be fully in force for all eligible clinicians, across all specialties. 

Along with other changes in reporting and performance, here are the performance category weights for MIPS eligible clinicians in 2024:

 

Weight for Standard

Weight for Small Practice (those with 15 or fewer clinicians)

Changes in 2024

Quality

30%

50%

No significant changes in scoring/reporting.

Cost

30%

30%

Allocating 30% of the total score to the cost performance category. 

Interoperability

25%

null

Allocating 15% of the total score to the IA performance category. 

Improvement Activity

15%

20%

Increase from a minimum of 90 continuous days to a minimum of 180 continuous days.

MIPs scores for 2024 are:

2024 Final Score

2026 Adjustment Score

0.0-18.75

Negative 9%

18.76-74.99

Negative MIPS payment adjustment greater than negative 9% and less than 0% on a linear sliding scale

75.0

0% adjustment

75.01-100

Positive MIPS payment adjustment greater than 0% on a linear sliding scale. The linear sliding scale ranges from 0 to 9% for scores from 75.00 to 100.00 This sliding scale is multiplied by a scaling factor greater than zero but not exceeding 3.0 to preserve budget neutrality.

Changes to Performance Categories

Clinical Quality Measures or Medicare CQM Performance Category and Data Completeness Threshold

Quality measures must be reported on a minimum of 75% of eligible cases for the year. This is an increase in the quality measures and counts for:

  • Electronic Clinical Quality Measures (eCQMs)
  • MIPS CQM
  • Qualified Clinical Data Registry (QCDR) measures 
  • Medicare Part B claims measures 
Improvement Activities

Improvement Activities account for 15% of the total MIPS score in the performance year 2024. Here are the changes for the improvement activities in the 2024 MIPS performance year: 

  • CMS has expanded the reporting criteria for improvement activities as a way to streamline and simplify reporting requirements and make it easier for clinicians to participate in MIPS. 
  • New improvement activities have also been added under eligible criteria, and these include activities towards telehealth, care coordination, and patient engagement. 
  •  
Cost Measure Performance Category

The Improved Cost Measure Performance Category applies only to clinicians using traditional MIPS reporting and is categorized as 0% for clinicians reporting via APM performance pathway. 

There are 25 cost measures available for this performance period, which include a range of procedures, chronic conditions, acute inpatient medical conditions, and chronic conditions, and population-based cost measures focused broadly on primary and inpatient care.

Promoting Interoperability Performance Category

While small practices may be exempt, other clinicians must stay informed about the two critical updates in 2024, ensuring a nuanced understanding of interoperability reporting. 

Currently Promoting Interoperability accounts for 25% of the final score depending on special statuses, hardship exception application, and APM participation. 

To participate in this performance category, eligible clinics are required to use an EHR that meets the certification criteria at 45 CFR 170.315, providing your EHR’s CMS identification code and attesting yes to several requirements. 

You must submit collected data for the required measures in each objective (unless an applicable exclusion is claimed) for the same 180 continuous days (or more) during the calendar year. 

Changes to Payment Models & Timelines

Medicaid Alternative Payment Model and Advanced Alternative Payment Model

Changes to Advanced APM Thresholds in 2024 will shift how an APM entity qualifies for participation in these MIPS alternative payment models. 

As a reminder, the Advanced APM is similar to the MIPS APM but with more criteria: 

  • The APM requires participants to use certified EHR technology.
  • The APM bases payment on quality measures comparable to those in the MIPS quality performance category.
  • The APM either: (1) requires APM entities to bear more than nominal financial risk for monetary losses OR (2) is a Medical Home Model expanded under Center for Medicare & Medicaid Innovation Authority (CMMI).

Eligibility for Advanced APM is based on past and current Medicare Part B claims and PECOS data and means you’re exempt from MIPS. 

CMS automatically reviews eligibility twice a year and posts the eligible clinicians on the QPP Participation Status Tool. Remember to subscribe to their listserv to stay up to date with these publications. Here is the list of APMs.

Clinicians can leverage PMs and EHRs to track and assess their performance against the updated Advanced APM thresholds. These tools assist clinicians in meeting evolving requirements and provide valuable insights, ultimately contributing to successful participation in MIPS APMs. 

Also note that there is a considerable push to transition to the MIPS Value Pathways (MVPs). Clinicians should consider making that transition sooner rather than later.

Medicare Physician Fee Schedule 2024

CMS issued the CY 2024 Physician Fee Schedule (PFS) final rule that announces policy changes for Medicare payments under the PFS and other Medicare Part B payment policy issues. See a summary of key provisions effective January 1, 2024

Notable updates include expanding potential fees to mental health, behavioral health, and certain telemedicine.

New Timelines for Requesting Targeted Review

CMS will open the targeted review submission period upon release of the MIPS final scores and keep it open for 30 days after MIPS payment adjustments are released. This would maintain an approximately 60-day period for requesting a targeted review.

2024 MIPS Payment Adjustment

Based on the performance reviews from 2022, clinics will see a payment adjustment required in their 2024 reporting year.

Safely Navigate the 2024 Quality Payment Program Updates With CareTracker

Practices can stay on top of all these changes with practice management software and Electronic Health Records (EHR) can simplify MIPS reporting, data collection, and analysis. 

These tools provide a systematic way to monitor performance metrics, identify areas for improvement, and ensure seamless compliance with evolving QPP requirements. 

For personalized guidance and consultation on optimizing your reporting strategy, contact Harris CareTracker today. Our experts can help you navigate healthcare reporting, monitor regulatory changes, and excel in QPP participation. 

Reach out to us for a consultation or to get more information on how Harris CareTracker can empower your practice in the ever-evolving world of healthcare.

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