The Centers for Medicare and Medicaid Services (CMS) recently released the 2023 Physician Fee Schedule final rule, with updates to the Quality Payment Program (QPP), for calendar year 2023 (the Final Rule). This article provides a summary of key, final changes to the QPP governing the traditional Merit-based Incentive Payment System (MIPS) program.
As a refresher, traditional MIPS comprises four performance categories: Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA). A provider’s score for each of these categories determines one’s total MIPS score and corresponding payment adjustment.
Allergy/Immunology Specialty Measure Set
CMS added two new quality process measures to the Allergy/Immunology Specialty Measure Set:
- 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.
- Adult Immunization Status: Percentage of members 19 years 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.
In addition, CMS removed two quality process measures from the Allergy/Immunology Specialty Measure Set for traditional MIPS reporting:
- Preventive Care and Screening: Influenza Immunization: Percentage of patients aged 6 months and older seen for a visit during the measurement period who received an influenza immunization OR who reported previous receipt of an influenza immunization.
- Pneumococcal Vaccination Status for Older Adults: Percentage of patients 66 years and older who have received a pneumococcal vaccine.
Performance Category Weights
For the 2023 performance year, the quality, cost, improvement activities (IA), and promoting interoperability (PI) performance categories will be generally weighted as follows. The percentages are the same as performance year 2022:
- 30% for the quality performance category
- 30% for the cost performance category
- 15% for the IA performance category
- 25% for the PI performance category
Performance Threshold
For the 2023 performance year, CMS kept the performance threshold at 75 points. Accordingly, clinicians and group practices must receive at least 75 points to avoid a negative payment adjustment for the 2025 payment year. Furthermore, there will NOT be a bonus for exceptional performance in 2023 (2022 is the last year of this bonus).
| Final Score for the 2023 Performance Year |
Payment Adjustment for the 2025 Payment Year |
|---|---|
| 75.01 – 100 points | Positive adjustment greater than 0%
Not eligible for additional payment for exceptional performance |
| 75 points | Neutral payment adjustment of 0% |
| 17.76 – 74.99 points | Negative payment adjustment between -9% and 0% |
| 0 – 18.75 points | Negative payment adjustment of -9% |
Data Completeness
CMS set data completeness at 70% for the 2023 performance year and at 75% for the 2024 and 2025 performance years. The College’s Advocacy Council opposed the increase of the MIPS data completeness requirement to 75% for the 2024 and 2025 performance years, arguing that such an increase is inconsistent with the agency’s goals of reducing administrative burden within the MIPS program.
Read the document from Health and Human Services for more information on the 2023 QPP Final Rule.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
