There have not been many changes for MIPS 2024. However, one of the biggest changes for 2024 is the exemptions. The public health emergency is now over. Therefore, all COVID-related exemptions are gone. Many doctors who attempted to claim an exemption in 2023 were denied. Which means that many offices that didn’t need to report for 2022 need to report for 2023.
Regarding exemptions moving forward, you can expect that there will not be exemptions available to your office unless there has been a natural disaster in your area and your area has been designated a federal disaster area. If you do not report MIPS for 2024 and you are required to report, you will experience a 9% cut in Medicare fees.
Go to https://qpp.cms.gov/ to check if you are required.
At this point, there are only a few weeks left to submit MIPS data for 2023. The deadline to submit with Registry Clearinghouse is February 28. If you still need support, email info@registryclearinghouse.com or use this link to set up a meeting. If you are required to report for 2023 and do not you will experience a 9% pay cut in Medicare fees starting January 1, 2025.
There are still 4 components for MIPS
- Cost
- Promoting Inter-operability
- Improvement Activities
- Quality Reporting
Cost
Cost is something that is in flux, that that it is something that is calculated by Medicare based upon your billing and looking at certain diseased states. Medicare was able to assign costs for a small number of podiatrists for 2022. Many of these offices did not find out about this until after the fact and some of these assignments weren’t necessarily appropriate. Starting in August when the final scores are being published, it is important that you check your account at the QPP website on a regular basis.
If anything seems out of the ordinary or if you do not think the score is correct, you need to contact CMS and request a targeted review. If they assign a cost to you that you do not believe is appropriate and you do not object, you may end up with a lower MIPS score than you are expecting. You only have a short time frame to appeal their decision, so it is important to review your account regularly.
As of today, there aren’t any cost measures that work well in podiatry, but that is expected to change relatively soon. The APMA is working with CMS to develop a cost measure that is applicable to podiatry. In fact, I have received an email from APMA asking if I would be a beta tester for cost measures. If you also receive a similar email, please respond to the email. Participate to help ourselves and our profession. This will help to prevent cost measures that are not applicable to podiatry from being assigned to you in the future.
If Cost has not been assigned for your office, the value of Cost will be reweighted to other categories.
Promoting Interoperability
This is how you use your EHR system to communicate with other doctors and patients. It is important to recall that if you are a small practice (15 or fewer clinicians) your office is automatically exempt from Promoting Interoperability. If you report for Promoting Interoperability, it will account for 25% of your MIPS score. If you are exempt (and do not file) it will account for 0% of your score and the value will be reassigned to other categories.
For 2024, Promoting Interoperability has increased from 90 days to 1 year. This means that your office must use the EHR for the full year. The Prescription Drug Monitoring Program Exclusion now accommodates clinicians who do not electronically prescribe Schedule II opioids. Looking ahead, in 2024, if you participate in a APM, you must use a certified EHR.
Quality Reporting
In 2023, we needed a data completeness of 70%. For 2024, we will need data completeness of 75%. It is important to note that CMS initially proposed moving the data completeness threshold to avoid a penalty to 82%. While they decided to delay this change, we can expect this threshold to continue to increase for future years making it more difficult to avoid a penalty.
11 Quality Measures have been removed
59 Quality Measures have been modified
11 Quality Measures have been added
A measure that many podiatrists used, Measure 128 – Preventative Care and Screening BMI is no longer available for 2024.
Improvement Activities
There were minor changes in improvement activities.
3 Measures have been removed
5 Measures have been added
These changes will not likely affect podiatrists.
Key Takeaways:
Check if you are required to report for MIPS at https://qpp.cms.gov/. Know that if you got an exemption previously, it is likely that your exemption will be denied for 2023.
The deadline to submit with Registry Clearinghouse is February 28, 2024. Email info@registryclearinghouse.com or schedule a meeting for assistance to submit.
Starting in August, check your account in QPP to ensure that no inappropriate costs were assigned to your office
Data completeness metrics are getting more stringent. Get set up early with monthly check-ins with Registry Clearinghouse to get the best possible MIPS score for 2024.
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