Home » The proposed quality payment program rule for 2023 is available now. Learn About Upcoming MIPS Reporting Changes

The proposed quality payment program rule for 2023 is available now. Learn About Upcoming MIPS Reporting Changes

by Team Techvilly

The Medicare Physician Fee Schedule (PFS) Proposed Rule, which contains proposed adjustments to the Quality Payment Program (QPP) for 2023 and subsequent performance years, was published by the Centers for Medicare and Medicaid Services (CMS) on July 7, 2022. The proposed rule modifies the Alternative Payment Models (APMs), the Accountable Care Organizations (ACOs), the new MIPS traditional Values Pathway (MVPs) structure, and the Merit-based Incentive Payment System (MIPS) program’s policies (ACOs). There will be a 60-day comment period that runs through September 6, 2022. Before a final regulation is published sometime in November, the plan might undergo more adjustments.

Small Changes to Traditional MIPS Proposed

The performance criteria of 75 MIPS points for the 2023 performance year would be established by the proposed regulation using the mean final score from the 2017 performance year. This implies that in order to prevent a negative payment adjustment in the 2025 payment year, clinicians and groups must again earn 75 MIPS points in 2023.

There will no longer be an additional performance threshold for exceptional performance in 2023, as stated in the 2022 MIPS Final Rule. Clinicians will no longer be eligible to receive an exceptional performance incentive after the 2022 performance year.

2023MIPS Performance category Weight

  • Quality 30.0%
  • Cost 30.0%
  • Promoting interoperability 25.0%
  • Improvement Activities 15.0%

2023 Small Practice Category Weights

  • Quality 40.0
  • Improvement Activities 30.0
  • Cost 30.0%

For small practices, CMS will keep automatically adjusting the weights of the performance categories Promoting Interoperability and Improvement Activities. Quality and Improvement Activities will each be weighted at 50% once Cost and Promoting Interoperability are both reweighted.

The additional adjustment for excellent performance has been eliminated in the planned payment modifications for 2025, which are shown in the table below. A MIPS score of 18.75 points or below would result in a full -9 percent penalty.

2023 Final Score                                        

zero to 18.75 points                   

-74.99 points, 18.76      

75 marks

0.75 to 100 points

Payment Modification 2025

more than 0% positive payment adjustment

Neutral payment modification

Adjustment for negative payments ranging from -9% to 0%

-9% in negative payment adjustment

Quality Updates for 2023 That Have Already Been Finalized:

Several policy modifications were adopted in the 2022 MIPS Final Rule and will take effect starting with the 2023 performance period:

Measures with a benchmark – For measures that can be measured against a benchmark, the 3-point floor is removed. These actions will be scored from 1 to 10. (New metrics in the first two reporting performance periods are not affected by this.)

Measures without a baseline no longer have to meet the 3-point minimum standard (except for small practices). These actions will not be given any points (small practices will continue to earn 3 points). (Administrative claims measures and new metrics in the first two performance periods available for reporting are not covered by this.)

Efforts that fall short of the case’s basic standards (20 cases) – Removed is the 3-point floor (except small practices). These actions will receive a score of 0 (small practices will continue to earn 3 points). (Administrative claims measures and new metrics in the first two performance periods available for reporting are not covered by this.) If the case minimum is not met, administrative claim score metrics are not considered.)

Value Pathways for MIPS (MVPs)

Initially starting with the 2023 performance year, CMS will gradually make MVPs available for reporting, as previously finalized in the 2022 MIPS final rule: Individual clinicians, single specialty groups, multispecialty groups, subgroups, and APM Entities may report MVPs for the performance years of 2023, 2024, and 2025. Individual doctors, lone specialized groups, subgroups, and APM Entities may report MVPs for the 2026 performance year and for subsequent years.

Modern APMs

CMS is recommending regulations to promote the use of alternative payment models (APMs). The suggestion would:

Make the 8% minimum on the Generally Applicable Nominal Risk requirement for Advanced APMs permanent and do away with its 2024 expiration date.

Apply the APM Entity’s participation in the Medical Home Model to the 50-clinician cap. The TIN/NPIs listed on the APM Entity’s participation list for each of the three QP determination dates would be used in the proposal to identify the physicians in the APM Entity (March 31, June 30, and August 31). This rule would go into force in 2023, the performance year.

Additionally, CMS is looking for feedback on the change from determining QP thresholds at the clinician level to the Advanced APM Entity level in the future.

Future Steps

To understand the potential impact on their reporting methods in 2023, clinicians should become familiar with the proposed QPP amendments as described in the 2023 Medicare PFS Proposed Rule. The proposed policy modifications are open for public comment through September 6, 2022, and the final regulation is anticipated to be published in November.

MD interactive will keep updating our website with new information so that physicians may stay up to date on program modifications. Clinicians and groups should keep putting their focus on adhering to the present reporting requirements because the 2022 MIPS reporting year is already well underway.

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