QPP MIPS undergoes several amendments every year for the upswing in the quality of care in the United States. CMS has proposed multiple changes in its Physician Fee Schedule final rule issued on November 01, 2022. This final rule for CY 2023 majorly covers the updates and policy changes for Medicare payments under the PFS and other Medicare Part B issues. All these new updates and policy changes will be implemented in MIPS reporting for CY 2023 on/after January 1, 2023.
Instead of including all those changes, here in this blog, we will be focusing only on the quality performance category. This category will constitute 30% of the total MIPS score. Therefore, it’s good to see what’s coming our way in MIPS measures for the quality category.
Quality Performance Category for MIPS Reporting
As expected, MIPS 2023 has revised the quality measures and some of its related policies for quality measures reporting. Here we will be discussing all these changes by comparing them with existing policies for MIPS 2022.
MIPS Quality Measure Inventory
The existing MIPS program for PY 2022 bound the providers to report for 200 quality measures in total. However, MIPS reporting 2023 includes only 198 measures in total with a set of 4 measures in the process. These four measures are proposed to be erased from PY 2023 but CMS is still working on this proposal. In other words, CMS has not yet finalized the fate of these measures. These four measures include the following:
| Quality # | Measure Title | Collection Type | Measure Type |
| 260 | Rate of Carotid Endarterectomy (CEA) for Asymptomatic Patients, without Major Complications (Discharged to Home by Post-Operative Day #2) | MIPS CQMs Specifications | High Priority; Outcome Measure |
| 261 | Referral for Otologic Evaluation for Patients with
Acute or Chronic Dizziness |
MIPS CQMs Specifications,
Medicare Part B Claims Measures Specifications |
High Priority; Process Measure |
| 275 | Inflammatory Bowel Disease (IBD): Assessment of
Hepatitis B Virus (HBV) Status Before Initiating Anti-TNF (Tumor Necrosis Factor) Therapy |
MIPS CQMs Specifications | High Priority; Process Measure |
| 439 | Age-Appropriate Screening Colonoscopy | MIPS CQMs Specifications | High Priority; Efficiency Measure |
Note: CMS has not finalized Qualified Clinical Data Registry (QCDR) measures in its rule-making procedure. Thereby, we haven’t considered them in the total 198 quality measures.
Anyhow, the quality measure inventory includes substantive changes in its 76 existing measures. Along with this, we have updates in the form of additions and removal of some other measures as well.
| Additions | ➢ 9 quality measures in total;
○ 1 composite measure ○ 1 new administrative claims measure ○ 5 high priority measures ○ 2 new patient-reported outcome measures ➢ Some measures in specific specialty sets |
| Removals | ➢ 11 quality measures are completely erased from MIPS 2023
➢ 2 quality measures for partial removal (removal from MIPS but considerable in MVPs) |
Scoring Benchmarks for Administrative Claim Measure
The general benchmark scoring process for MIPS reporting 2023 differs from 2022.
MIPS 2022 decides the scoring benchmarks by the comparison of healthcare data from the baseline period 2 years before the performance period. If the healthcare data is unprocurable for being considered as a historical benchmark, the calculation of the performance period benchmark is the next step. On the other hand, QPP will prefer administrative claims measures mainly against performance period benchmarks for MIPS Quality Measures scores in PY 2023.
Definition Expansion for High-Priority Measures
ICD’s revision 10 provides the expandability to the already existing coding procedure. In the same way, MIPS healthcare reporting for CY 2023 gives an extension to the already present definition of high priority measures.
MIPS 2022 counts the following as part of high-priority measures:
- Outcome quality measure (both intermediate-outcome and patient-reported outcome)
- Patient safety quality measure
- Efficiency quality measure
- Patient experience quality measure
- Care coordination quality measure or
- Opioid-related quality measure
- Appropriate use of quality measure
CMS has added diversification by considering health equity-related quality measures for PY 2023.
Case-Mix Adjustment for CAHPS for MIPS Survey
Both MIPS’s existing policy and its policy for PY 2023 have case-mix adjustments. Mainly, the purpose of case-mix adjustments is to find a prediction of a hospital’s ratings for a standard patient or population. All this happens by using statistical models for predictions.
The case-mix adjusters for PY 2022 are given below:
- Age
- Education
- Proxy response
- Medicaid dual eligibility
- Medicare’s low-income subsidy eligibility
- Self-reported general and mental health status
- Asian language survey completion (beginning 2022)
For CY 2023 reporting, CMS has a better plan for comparing the performance of all MIPS groups. It portrays the language preference and response pattern of participants on the same canvas. For this, it has selected a case-mix adjustor for “Asian language survey completion”. This adjuster replaces the “Asian language survey completion” with variables like;
- Asian language is spoken at home,
- The Spanish language is spoken at home
- Other languages is spoken at home Data Completeness Requirement for Different Collection Types
As per MIPS’s existing policy, all participants are bound to report 70% of denominator-eligible encounters for performance periods 2022 and 2023. PFS’s final rule doesn’t have any changes for the low-volume threshold for PY 2023. Anyways, CMS is intending to raise this performance threshold for data completeness to 75% for the 2024 and 2025 performance periods.
This policy only applies to Electronic Clinical Quality Measures (eCQMs), MIPS Clinical Quality Measures (MIPS CQMs), Medicare Part B Claims Measures, and QCDR Measures. However, CMS Web Interface measures have a little relief as the data completeness requirements are changed for them. CMS Web Interface is open for Medicare Shared Savings Program Accountable Care Organizations (ACOs) reporting through the APM Performance Pathway (APP).
Conclusion
That’s all about the MIPS reporting 2022 for the quality category in the PFS final rule. It’s better to check out the quality category for MIPS 2023 before selecting your quality measures. This will not only save time but also you will be able to devise striking strategies for your MIPS healthcare reporting before time.
