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This payment track builds on traditional fee-for-service payments by adjusting them up or down based on a physician’s performance.

ACP asked and CMS responded! Due to the COVID-19 public health emergency, CMS is providing broad relief from MIPS penalties through 2024. Clinicians, groups, and virtual groups may submit a hardship exception����for re-weighting any or all MIPS performance categories through January 2, 2024. Clinicians should note that if data is received on their behalf (such as by an EHR vendor, billing service, or registry) for two or more categories, this will supersede the exception and they will receive a score and accompanying payment adjustment.��

Major 2023 Changes:

• The weight for all MIPS categories will remain the same as 2022
• Performance threshold
  • Minimum performance threshold of 75 MIPS points to avoid any MIPS penalties
  • The 2022 performance year/2024 payment year was the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance
• Payment adjustments
  • Maximum payment adjustments remain the same at +/- 9%
  • This will be applied towards a clinician’s 2024 Medicare Part B payments for covered professional services
  • If a MIPS eligible clinician did not participate in MIPS in 2022, they will receive a negative payment adjustment of –9% in 2024
  • The 2022 performance year/2024 payment year was the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance
• Complex Patient Bonus
  • CMS will continue doubling the complex patient bonus for the 2021 MIPS performance year. The bonus points will be added to the final score
  • Complex patient bonus increasing the bonus to a maximum of 10.0 points
• MIPS Value Pathways (MVPs)
  • Clinicians now have the option to report MIPS through MIPS Value Pathways (MVPs). In addition to the seven existing MVPs, CMS finalized 5 new MVPs including the Promoting Wellness MVP which developed from an ACP proposal on preventative care
  • The Quality Measure Set includes 9 new measures
  • The Data Completeness Threshold remains at 70% for 2023 but will increase to 75% for calendar year (CY) 24 and CY25
  • The definition of “High Priority Measure” has been expanded to include health equity-related quality measures
  • The 2023 Consumer Assessment of Healthcare Providers and Systems (CAHPS) for the Merit-based Incentive Payment Systems (MIPS) is open until June 30, 2023, at 8:00 PM ET. Groups and APM Entities (other than Shared Savings Program ACOs that choose to report the APP must register because this survey is a required measure under APP. For information on registration and how to register, visit the .
  • The Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) registration for the 2023 performance year is open until November 30, 2023, at 8:00 PM ET. Learn more about MVPs, the MVPs finalized for the 2023 performance year, registration information, and . Please note that you will have to email your complete registration to QPP@cms.hhs.gov with the subject line MVP Registration.

Please visit our Physician & Practice Timeline to stay on top of these deadlines.

Small and Rural Hospitals

The CMS QPP Small, Underserved, and Rural Support (SURS) initiative ended on February 15, 2022, after five years of direct support. Sign up for the monthly to receive information tailored to small practices. Read the to get started with 2023 MIPS participation. Read ACP’s request to extend critical technical program for QPP-SURS.

Beginning with performance year 2023, small practices will receive automatic reweighting of the Promoting Interoperability performance category to 0%, whether they choose to participate as an individual or as a group.

You will no longer need to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application to request reweighting in this performance category.

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The small practice category weight��reflects��the��finalized performance category reweighting and redistribution��policies��when the Promoting Interoperability performance category is reweighted.��When the cost and Promoting Interoperability performance categories are reweighted,��Quality and Improvement Activities will be equally weighted at 50%. When both Quality and Promoting Interoperability performance categories are reweighted,��Cost and Improvement Activities will be equally weighted at 50%.��

2023 Low Volume Threshold

To be eligible for MIPS, clinicians and practices must exceed the low-volume threshold (LVT) during both segments of the MIPS Determination Period to be eligible for MIPS. ��Participation in MIPS is required if, in both 12-month segments of the MIPS Determination Period if you:

• Bill more than $90,000 for Medicare Part B covered professional services, and
• See more than 200 Medicare Part B patients, and;
• Provide more than 200 covered professional services to Medicare Part B patients

Segment 1 of the MIPS Determination covers October 1, 2021, until September 30, 2022, and initial eligibility is released on the QPP site in December 2022.

Segment 2 of the MIPS Determination covers October 1, 2022, until September 30, 2023, and final eligibility is released on the QPP site in December 2023.��

MIPS - Scoring

The MIPS scoring is a composite score of the 4 performance categories:

• - worth 30% of the total. Must report on 6 measures worth up to 10 points each and scored against benchmarks based on collection type (previously known as reporting method). Bonus points for clinicians in small practices who submit 1 measure either individually or as a group.
• - worth 25% of the total. 2015 CEHRT required, must report all measures (or claim exemption).
• - worth 15% of the total MIPS score. Clinicians or groups must earn a total of 40 points.��High weighted activities are worth 20 points and medium weighted activities are worth 10 points. Small, rural, or HPSA clinicians or groups earn double points. PCMH/PCSP get full credit. Only 1 clinician in the group has to perform the activity.
• - worth 30% of the total score. Based on Medicare Part A and B claims data. No reporting necessary as this category is calculated by CMS.

Read more on the .

MIPS Value Pathway (MVP)

MVPs are similiar to MIPS, except all of the measures and activities across all four performance categories will be centered around a particular specialty, condition, or patient population. With MVPs, CMS aims to create more harmony across the MIPS performance categories, lessen data reporting, increase clinical relevance, and facilitate a glidepath to APMs. Due to the COVID-19 PHE, CMS delayed implementation of an initial set of MVPs until at least PY 2023. MVPs are currently optional, but CMS may eventually require participation in MIPS through either MVPs or the new APP (see below). CMS is working with stakeholders to design MVP bundles. ACP submitted two MVP proposals on preventive care and chronic disease management.��In the 2023 final rule, CMS finalized 5 new MVPs including the Promoting Wellness MVP which developed from the aforementioned ACP proposal on preventative care. We continue to actively engage with CMS on design and implementation of these specific MVP proposals and MVPs overall. For more information, check out the following:

• (ACP member login required)
• ACP analysis of the 2023 PFS/QPP rule (ACP member login required)

MIPS APM Performance Pathway (APP)

In 2021, CMS replaced the “MIPS APM scoring standard” with the new “MIPS APM Performance Pathway (APP).” The APP is designed to be an optional pathway for clinicians that participate in an APM but still participate in MIPS either because: 1) their model does not meet the criteria to be considered an “Advanced APM;” or 2) they fall short of Qualified Advanced APM Participant (QP) Thresholds. Category weights under the APP resemble those under the APM Scoring Standard: Cost: 0%; Promoting Interoperability: 30%; Improvement Activities: 20%; and Quality: 50% (unless reweighting applies). Under the APP, data can be reported at the APM Entity, group, or clinician level. All clinicians under the APP will be scored on the same six quality measures (if available/applicable). For more, read ACP’s analysis (ACP Member login required) of the 2023 PFS/QPP final rule and access this CMS fact sheet.

MIPS Resources

ACP Resources:

• Visit ACP's COVID-19 advocacy page for the latest on what ACP is doing to protect and provide relief for clinicians during these uniquely challenging circumstances.

CMS Resources:

• • 2023 Improvement Activities List
• ��
• For specifics in each category, including scoring, measures (for each reporting method), activities, and specifications for each measure/activity, search the��.

Have more questions? Email us at policy-regs@acponline.org.