If you’re participating in MIPS in 2023, take note. CMS removed two popular quality measures from traditional MIPS – and from the allergy/immunology quality specialty measures set – in 2023:
- Preventive Care and Screening: Influenza Immunization
- Pneumococcal Vaccination Status for Older Adults
These two measures were replaced by a new one that is much more difficult for allergists to report. The new measure, Adult Immunization Status, measures the percentage of patients 19 years of age and older who are up to date on four recommended routine vaccines: influenza; tetanus and diphtheria (Td) or tetanus; diphtheria and acellular pertussis (Tdap); zoster; and pneumococcal. To report this measure, allergists must track all four vaccines for each patient.
The traditional Merit-based Incentive Payment System (MIPS) includes four performance categories:
- Promoting Interoperability (PI)
- Improvement Activities (IA)
Performance across these MIPS performance categories will result in a MIPS final score, which determines whether CMS will apply a negative, neutral, or positive MIPS payment adjustment to your reimbursements. MIPS reporting for 2023 will determine payment adjustments in 2025.
For the 2023 performance year, CMS will generally weigh the performance categories for a MIPS-eligible clinician, group and virtual group (collectively, “providers”) as follows:
- 30% for the Quality performance category
- 30% for the Cost performance category
- 25% for the PI performance category
- 15% for the IA performance category
Quality Performance Category
The Quality Performance category assesses quality of care based on measures of performance. For the 2023 performance period, providers may select from approximately 200 non-Qualified Clinical Data Registry (QCDR) quality measures, as well as additional QCDR measures. In general, providers must report data on at least six quality measures, including one outcome measure (or one high-priority measure if an applicable outcome measure is not available). Providers have the option of submitting data on certain measures within a specialty measure set, which is a group of quality measures applicable to a specific specialty.
For each quality measure, you must report performance data for at least 70% of the denominator eligible cases (i.e., data completeness threshold). If the data completeness requirement is not met, you’ll receive 0 points for the measure unless you are in a small practice.
For clinicians in small practices (15 or fewer clinicians) who submit at least one measure, six bonus points will be added to the quality performance category score. In general, CMS will award three points to small practices for submitting:
- Quality measures without an available benchmark.
- Quality measures that don’t meet the data completeness or case minimum requirements.
Specialty Measure Sets
Specialty Measure Sets help providers identify measures that may be applicable to their practice. Providers who choose to submit a specialty measure set must report data on at least six measures within that set. For the 2023 performance period, the Allergy/Immunology Specialty Measure Set contains 13 measures:
High-Priority Measure: Process
- Adult Sinusitis: Antibiotic Prescribed for Acute Viral Sinusitis (Overuse)
- Adult Sinusitis: Appropriate Choice of Antibiotic: Amoxicillin With or Without Clavulanate Prescribed for Patients with Acute Bacterial Sinusitis (Appropriate Use)
- Closing the Referral Loop: Receipt of Specialist Report
- Documentation of Current Medications in the Medical Record
- HIV Medical Visit Frequency
- Use of High-Risk Medications in Older Adults
High-Priority Measure: Outcome
- Optimal Asthma Control
- HIV Viral Load Suppression
- Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Tobacco Use and Help with Quitting Among Adolescents
- NEW – Screening for Social Drivers of Health (SDOH) – Percentage of patients 18 years and older screened for food insecurity, housing instability, transportation needs, utility, difficulties, and interpersonal safety
- NEW – Adult Immunization Status – Percentage of members 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
Providers should explore available quality measures to determine which ones best fit their practice. For more information on MIPS measures, please refer to the Quality Payment Program’s (QPP) website.
For additional information on the MIPS program in general, please refer to the QPP Resource Library. Those in smaller practices can refer to special policies for small practices.
Important! You are able to apply for a 2023 MIPS Extreme and Uncontrollable Circumstances (EUC) hardship exception due to COVID-19 to avoid up to a -9% MIPS penalty in 2025. CMS is expected to release the hardship exception application in the coming weeks and it will remain open until Jan. 2, 2024.
We will continue to monitor and report updates on this issue. The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.