The Centers for Medicare and Medicaid Services (CMS) recently released its final rule with updates to the Quality Payment Program (QPP) for 2024 (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.
Performance Category Weights
For the 2024 performance year, the Quality, Cost, IA, and PI performance category weights will remain the same as in 2023:
- 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
Due in part to College advocacy, CMS kept the performance threshold at 75 points for 2024. Accordingly, clinicians and group practices must receive at least 75 points to avoid a negative payment adjustment for the 2026 payment year.
| Final Score for 2024 Performance Year | Payment Adjustment for 2026 Payment Year |
|---|---|
| 75.01 – 100 points | Positive adjustment greater than 0%. The 2022 performance year was the last year for the additional positive payment adjustment for exceptional performance. |
| 75 points | Neutral payment adjustment of 0% |
| 18.76 – 74.99 points | Negative payment adjustment between -9% and 0% |
| 0 – 18.75 points | Negative payment adjustment of -9% |
CMS had proposed to increase the performance threshold to 82 points. The proposed establishment of a higher, more rigorous performance threshold would have increased undue administrative burden on physicians. The College’s Advocacy Council strongly opposed the agency’s proposal to increase the performance threshold to 82 points for the 2024 performance period, based on a three-year average of performance data from 2017 to 2019.
Data Completeness
CMS previously finalized a policy increasing the data completeness threshold to 75% for the 2024 and 2025 performance periods. Thanks in part to College advocacy, CMS is maintaining data completeness at 75% through the 2026 performance period. The agency did not finalize its proposal to increase the data completeness criteria threshold to 80% for the 2027 performance period. The College’s Advocacy Council opposed the proposed increase of the MIPS data completeness requirement.
Quality Measures Removed from the MIPS Program
The agency removed the following quality measures from MIPS for the 2024 performance period and future years:
- Quality ID #110: Preventive Care and Screening: Influenza Immunization: Percentage of patients aged six 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.
- Quality ID #111: Pneumococcal Vaccination Status for Older Adults: Percentage of patients 66 years of age and older who have received a pneumococcal vaccine.
- Quality ID #128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan: Percentage of patients aged 18 years and older with a BMI documented during the current encounter or within the previous twelve months AND who had a follow-up plan documented if the most recent BMI was outside of normal parameters.
- Quality ID #402: Tobacco Use and Help with Quitting Among Adolescents: The percentage of adolescents 12 to 20 years of age with a primary care visit during the measurement year for whom tobacco use status was documented and received help with quitting if identified as a tobacco user.
Amended Quality Measures
The agency finalized substantive changes to the following quality measures.
- Quality ID #226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention: Currently, this measure describes the percentage of patients aged 18 years and older who were screened for tobacco use one or more times within the measurement period AND who received tobacco cessation intervention during the measurement period or in the six months prior to the measurement period if identified as a tobacco user. CMS amended the quality measure by lowering the denominator eligible age to 12 years and older to allow for the inclusion of adolescents into the measure’s denominator.
- Quality ID #398: Optimal Asthma Control: CMS updated the measure criteria by including patients who were permanent nursing home residents at any time during the performance period within the denominator of this measure. Patients within a nursing home should still be assessed for the quality action within this measure as it supports overall health and quality of life.
Allergy/Immunology Specialty Measure Set
CMS added two new quality measures to the Allergy/Immunology Specialty Measure Set:
- Quality ID #498: Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health-related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least one of their HRSNs within 60 days after screening.
- Quality ID #503: Gains in Patient Activation Measure (PAM®) Scores at 12 Months: The Patient Activation Measure® (PAM®) is a short questionnaire that assesses an individual´s knowledge, skills, and confidence for managing their health and health care. The measure assesses individuals on a 0-100 scale that converts to one of four levels of activation, from low (1) to high (4). The PAM® performance measure (PAM®-PM) is the change in score on the PAM® from baseline to follow-up measurement.
Promoting Interoperability Performance Category
Currently, the performance period is a minimum of 90 continuous days within the calendar year. CMS will increase the performance period to a minimum of 180 continuous days within the calendar year starting in 2024.
Alternative Payment Model (APM) Incentive Payment
2023 was the last year of the APM Incentive Payment of 3.5%. Instead, beginning with the 2024 performance year, qualifying APM participants will receive a higher payment rate (calculated using the differentially higher “qualifying APM conversion factor”) than non-APM participants. In 2024, APM participants will receive a positive 0.75% Medicare conversion factor (CF) update, while others will receive only a 0.25% CF update.
More information on the 2024 QPP Final Rule can be accessed at https://www.federalregister.gov/d/2023-24184.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
