CMS published proposed updates to the Quality Payment Program (QPP) for calendar year 2024 (the Proposed Rule). This article provides a summary of key proposals and changes to the traditional Merit-based Incentive Payment System (MIPS) program that will impact allergists. The Advocacy Council will submit comments to CMS on behalf of our specialty.
Key Takeaway: it’s getting much harder to successfully report for MIPS, and allergists need to take MIPS reporting seriously to avoid a penalty. Penalties for not reporting are steep – now 9%.
In the 2021 program year, allergy/immunology had one of the highest MIPS penalty rates of all specialties: 4.9% of allergists received a MIPS penalty. An additional 14.4% of allergists met the performance threshold of 60 points and received no penalty or bonus. In 2023, all allergists with that score (60 points) would receive a penalty due to the higher performance threshold of 70 points.
Additionally, in 2021, 14.9% of allergists received a MIPS score of 60-85, which earned them a bonus at that time. But with the proposed higher performance threshold of 82 points in 2024, many allergists in that performance range (60-81) would receive a penalty going forward.
Which of the proposed changes to MIPS in 2024 will impact allergists?
MIPS Refresher
As a refresher, traditional MIPS comprises four performance categories: quality, cost, Promoting Interoperability (PI), and improvement activities (IA). Achievement across 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 2024 will determine payment adjustments in 2026.
Under the Proposed Rule, for the 2024 performance year, weighting for the quality, cost, IA, and PI performance categories would remain the same as for 2023, and generally be as follows:
- 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 2024 performance year, CMS proposes to increase the performance threshold by 7% from 75 points to 82 points. Allergists will receive a positive MIPS payment adjustment only if their final score exceeds the performance threshold. Accordingly, this proposed performance threshold would make it more difficult for allergists to avoid a MIPS-related penalty. The Advocacy Council will strongly oppose this proposed increase.
| 2024 Final Score | 2026 Payment Adjustment |
|---|---|
| 82.01 – 100 points | Positive adjustment greater than 0% on a linear sliding scale. The linear sliding scale ranges from 0 to 9% for scores from 86 to 100.00. This sliding scale is multiplied by a scaling factor not exceeding 3.0 to preserve budget neutrality. |
| 82 points | Neutral payment adjustment |
| 20.51 – 81.99 points | Negative payment adjustment greater than -9% on a linear sliding scale |
| 0 – 20.5 points | Negative payment adjustment of -9% |
Data Completeness
The data completeness requirement is set to increase from 70% in 2023 to 75% in 2024 and 2025. The agency is proposing to maintain the data completeness criteria threshold at 75% for the 2026 performance period. For the 2027 performance period, CMS proposes to increase the data completeness criteria threshold from 75% to 80%. These higher thresholds would increase provider burden, and the Advocacy Council will oppose them, beginning with the increase for 2024.
MIPS PI Performance Period
Under the Proposed Rule, the PI performance period for 2024 would increase to 180 continuous days within the calendar year from 90 continuous days in 2023.
Allergy/Immunology Specialty Measure Set
The quality performance category assesses quality of care based on measures of performance. Under the Proposed Rule, for the 2024 performance period, providers would be able to select from 200 non-Qualified Clinical Data Registry (QCDR) quality measures and 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, but they are not required to do so. 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, including at least one outcome measure. Allergists should explore available quality measures to determine which ones best fit their practice.
For the 2023 performance period, the Allergy/Immunology Specialty Measure Set contains thirteen 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
- Use of High-Risk Medications in Older Adults
- Documentation of Current Medications in the Medical Record
- Screening for Social Drivers of Health (SDOH)
- HIV Medical Visit Frequency
High-Priority Measure: OUTCOME
- Optimal Asthma Control
- HIV Viral Load Suppression
Process Measure
- Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention – Proposed denominator change for 2024*
- Tobacco Use and Help with Quitting Among Adolescents – Proposed for removal in 2024**
- Adult Immunization Status
*Proposed Amendment
In addition, CMS proposes to change the denominator of the Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention quality measure. Currently, this quality 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 is proposing to broaden the denominator by lowering the age to 12 years old.
** Proposed Removal
As noted above, CMS proposed to remove the “Tobacco Use and Help with Quitting Among Adolescents” quality measure from the traditional MIPS program.
Proposed Addition
CMS proposes to add two new measures to the Allergy/Immunology Specialty Measure Set:
- “Connection to Community Service Provider” (CSP). This measure describes the 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 CSP for at least one of their HRSNs within 60 days after screening.
- “Gains in Patient Activation Measure (PAM) Scores at 12 Months.” The PAM is a 10- or 13-item 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 is the change in score on the PAM from baseline to follow-up measurement.
Find more information on the 2024 QPP Proposed Rule.
Coming next is our analysis of the proposed changes to the 2024 Medicare Physician Fee Schedule. Stay tuned for our exclusive review!
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
