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NEW MIPS and QPP 2023 Final Rule: High-Level Summary


CMS MIPS HHS Quality 2023

On November 1, 2022, the Centers for Medicare and Medicaid Services (CMS) officially released the 2023 Quality Payment Program (QPP) final rule. The 3,304 page final rule contained many changes that will take place in the 2023 MIPS performance year and beyond.

This blog post breaks down the final changes to the QPP and MIPS for 2023.

Performance Thresholds

  • Threshold to Avoid a Penalty: 75 points (no change from 2022)
  • Exceptional Performance Threshold: Retired (as required by law, 2022 was the last year)

Category Weights

CMS is keeping performance category weights the same in 2023. 

2022CategoryWeights

Quality Category

The following policy changes will begin in 2023:

  • eCQM Reporting
    • For eCQM reporting, you EHR must be certified to the 2015 Edition Cures Update by the last day of the performance period.
  • Measure Scoring: Removal of the 3-point Floor
    • For large practices (>15 clinicians)
      • Measures that have a benchmark, meet case minimum, and meet data completeness will be scored on a 1-10-point scale instead of a 3-10-point scale.
      • Measures not meeting the above criteria will earn 0 points.
    • For small practices 
      • Measures that have a benchmark, meet case minimum, and meet data completeness will be scored on a 1-10-point scale instead of a 3-10-point scale.
      • Measures not meeting the above criteria will earn 3 points.
  • Bonuses 
    • No change to the small practice bonus or the improvement score bonus.

CMS finalized the following for the 2024-2025 performance years:

  • Data Completeness Threshold
    • Increasing from 70% to 75%.

Cost Category

CMS finalized the addition of an improvement score bonus, much like that available in the Quality category. It will be based on measure-specific score improvements. The available bonus will be up to 1% of the Cost category score.

Improvement Activities

No significant changes for scoring or reporting this category. There are, however, several significant changes to the list of improvement activities (IAs), including:

  • Four new IAs, including Create and Implement a Language Access Plan (high-weighted) and COVID-19 Vaccination for Practice Staff (medium-weighted).
  • Five changes to existing IAs, including Use of QCDR data for ongoing practice assessment and improvements. 
  • Six IA removals, including use of QCDR for feedback reports that incorporate population health (high-weighted).

Promoting Interoperability (PI)

In 2020, CMS finalized that clinicians can only use certified electronic health record technology (CEHRT) that meets certification requirements. On December 31, 2022, to remain certified, an EHR must meet the conditions of the Cures edition update. Because of this, you must be using an EHR with Cures Update functionality by the first day of your 90-day PI performance period in 2023. Your EHR must be certified to the 2015 Edition Cures Update by the last day of the performance period.

The following policy changes will begin in 2023:

  • New Required Measure: Query of Prescription Drug Monitoring Program
    • This was previously an optional bonus measure.
    • This measure is being expanded to include Schedule II opioids and Schedule III or IV prescriptions (previously only Schedule II).
    • There are 3 finalized exclusions:
      • You are unable to electronically prescribe Schedule II opioids and Schedule III and IV drugs under applicable law during the performance period.
      • You write fewer than 100 permissible prescriptions during the 90-day performance period.
      • *NEW for 2023 ONLY* Querying a PDMP would impose an excessive workflow or cost burden prior to the start of your selected 90-day performance period in 2023.
  • Change to the Public Health and Clinical Data Registry Objective
    • You will be required you to report which stage of engagement you are in with the registries you attest to for PI ("Pre-production and Validation" or "Validated Data Production").
    • You will only be allowed to be in Pre-production and Validation for a maximum of 1 year, after which you would need to progress to Validated Data Production or lose credit.
      • The exception is if you switch between 1 or more registries. Those new registries that you switched to will be allowed to be in Pre-production and Validation for 1 year. attest to both the Immunization Registry Reporting measure and the Electronic Case Reporting measure to get credit. (Unless an exclusion applies).
    • For the required Electronic Case Reporting measure, exclusion 4 (your CEHRT that is not certified to the electronic case reporting certification criterion at § 170.315(f)(5) prior to the start of the performance period they select in CY 2022) will not be available beginning in 2023.
  • New Option to Satisfy the Health Information Exchange Objective
    • In addition to currently available options (Sending and Receiving measures or the Bilateral Exchange measure), CMS has added a third option: Participation in the Trusted Exchange Framework and Common Agreement (TEFCA).
      • TEFCA is new this year and very few avenues of participation exist. It is unlikely that many clinicians will be able to use this option in 2023.
  • New PI Category Scoring to Accommodate New Measure
2023 Proposed PI Scoring

MIPS Value Pathways (MVPs)

MVPs will roll out in 2023 for the first time. There are no MVPs currently relevant to our specialist clients. We will discuss MVP scoring in a future blog.


Next Steps

  • Review our Top 2023 Final MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.
  • Subscribe to our blog to get alerts on this and other important issues. Please use the pop-up form on our blog pages to subscribe.
  • If you are not a MarsdenAdvisors client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

If you want hands-on, personalized assistance, contact us and we will have your back. 

 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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