2023 MIPS Proposed Rule
At the end of July, CMS released its 2023 Proposed Rule for MIPS Reporting. There were some notable changes proposed, including additional MVP options and measure changes for the Promoting Interoperability category. They have not proposed any changes to the scoring or minimum thresholds for 2023, however CMS did suggest it was open to change for the 2024 reporting period.
MIPS Value Pathways
As previously stated by CMS, MVP development and expansion are the main focus of MIPS moving forward. Keep in mind that this does not exclude future changes within Traditional MIPS reporting. Though they are not proposing any changes to the reporting foundations of the MVP pathway, they have been working on the expansion of MVPs available for reporting. In addition to the 7 MIPS Value Pathways that have already been established in the 2022 Final Rule, CMS is recommending 5 new MVPs for the 2023 reporting year. These include:
- Optimal Care for Kidney Health
- Advanced Cancer Care
- Optimal Care for Patients with Episodic Neurologic Conditions (ex. Epilepsy)
- Supporting Care for Neurodegenerative Diseases (ex. Parkinson’s)
- Promoting Wellness (Primary Care)
The 7 MVPs that have already been approved for 2023 reporting include:
- Rheumatology: Advancing Rheumatology Patient Care
- Stroke Care and Prevention: Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
- Heart Disease: Advancing Care for Heart Disease
- Chronic Disease Management: Optimizing Chronic Disease Management
- Emergency Medicine: Adopting Best Practice and Promoting Patient Safety within Emergency Medicine
- Lower Extremity Joint Repair: Improving Care for Lower Extremity Joint Repair
- Anesthesia: Patient Safety and Support of Positive Experience with Anesthesia
Multispecialty groups are not required to form subgroups until 2026 for MVP reporting, but they are proposing that a clinician would only be allowed to register for one subgroup per TIN (scores will be calculated at the TIN level).
Traditional MIPS – Quality
CMS has proposed very little overall changes for traditional MIPS. Category weights, data completeness threshold and performance threshold will remain the same for 2023 reporting. They are already proposing, however, to increase the data completeness threshold from 70% to 75% in 2024 and 2025.
CMS is proposing the addition of 9 new quality measures:
- Psoriasis – Improvement in Patient-Reported Itch Severity
- Dermatitis – Improvement in Patient-Reported Itch Severity
- Adult Immunization Status
- Percentage of patients 19 years of age and older who are up to date on recommended routine vaccines for influenza; tetanus and diphtheria (Td) or tetanus, diphtheria, and acellular pertussis (Tdap); zoster; and pneumococcal.
- Kidney Health Evaluation
- Screening for Social Drivers of Health
- Adult Kidney Disease: Angiotensin Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy
- Appropriate Intervention of Immune-Related Diarrhea and/or Colitis in Patients Treated with Immune Checkpoint Inhibitors
- Mismatch Repair (MMR) or Microsatellite Instability (MSI) Biomarker Testing Status in Colorectal Carcinoma, Endometrial, Gastroesophageal, or Small Bowl Carcinoma
- Risk Standardized Acute Cardiovascular-Related Hospital Admission Rates for Patients with Heart Failure under Merit-based Incentive Payment System
CMS is proposing the removal of 15 measures:
- #076 – Prevention of Central Venous Catheter (CVC)
- #119 – Diabetes: Medical Attention to Nephropathy
- #258 – Rate of Open Repair of Small or Moderate Non-Ruptured Infrarenal Abdominal Aortic Aneurysm (AAA) without Major Complications
- #260 – Rate of Carotid Endarterectomy (CEA) for Asymptomatic Patients, without Major Complications
- #261 – Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
- #265 – Biopsy Follow-Up
- #275 – Inflammatory Bowel Disease (IBD): Assessment of Hepatitis B Virus (HBV) Status Before Initiating Anti-TNF (Tumor Necrosis Factor) Therapy
- #323 – Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Routine Testing After Percutaneous Coronary Intervention (PCI)
- #375 – Functional Status Assessment for Total Knee Replacement
- #425 – Photo documentation of Cecal Intubation
- #439 – Age-Appropriate Screening Colonoscopy
- #455 – Percentage of Patients Who Died from Cancer Admitted to the Intensive Care Unit (ICU) in the Last 30 Days of Life (lower score = better)
- #460 – Back Pain After Lumbar Fusion
- #469 – Functional Status After Lumbar Fusion
- #473 – Leg Pain After Lumbar Fusion
CMS is also proposing to move Measure 110 (Influenza Immunization) and Measure 111 (Pneumococcal Vaccination Status for Older Adults) to MVP reporting only and replacing both the measures with the new Adult Immunization measure.
Traditional MIPS – Promoting Interoperability
CMS will be removing the Electronic Case Reporting exclusion stating the EHR is uncertified for eCR reporting, but they will be keeping the automatic PI reweighting for small practices in place. CMS has proposed adding a 3rd option to the Health Information Exchange measure called the Trusted Exchange Framework and Common Agreement (TEFCA). They have also proposed making Querying the PDMP a required measure (an exclusion will be available to providers who do not prescribe controlled substances). Both of these additions to the PI category will be changing the scoring breakdown for the entire category.
|PDMP (optional)||10 (bonus)||PDMP||10|
|HIE Send/Receive||40 (20 each)||HIE Send/Receive||30 (15 each)|
|HIE Bi-Directional||40||Participation in TEFCA||30|
|Patient Portal||40||Patient Portal||25|
|Public Health||10||Public Health||25|
|Public Health Bonus||5||Public Health Bonus||5|
2022 will be the last year that the COVID hardship is available for application, increasing the importance of practices being prepared to make necessary changes and implement MIPS workflows earlier on. The 2023 Final Rule is expected to release in late November or early December 2022.