The Merit-based Incentive Payment Systems (MIPS) program is entering its eighth year of operation, and it is still a hotbed of confusion, anxiety, and—depending on who you ask—misinformation. These feelings are largely because participation in MIPS is extremely dependent on the specialty, group, reporting option and clinician’s commitment to continued participation. For several years, providers were offered an exemption to the program due to the COVID-19 pandemic, but 2023 will not likely continue to enjoy this backstop. To help dispel some of the stress of navigating MIPS, this alert will walk through the requirements of 2023 reporting and be a resource to review if you have any question about how you need to participate next year.
MIPS Category Review
At the high level, there are only two categories that need to be considered under MIPS: Quality and Improvement Activities. These two categories comprise 70 percent of your overall MIPS composite score, as Cost is automatically calculated by CMS, based on your billing.
When added together, these three categories must total 75 points or more to avoid a penalty in 2023. For example, at the end of the year when each category score is calculated, and your results are 80 percent in Quality, 100 percent in Improvement Activities, and CMS awarded 75 percent in Cost, your total would be as follows:
If the total score is above or below the 75-point threshold, bonuses or penalties will be assessed on a linear sliding scale. This may seem daunting, but you can be excluded from the entire program if you bill less than $90,000 in traditional Medicare allowed per provider. If you are curious about your status, click here for the MIPS participation lookup tool. We will review this on your behalf, as well, but feel free to check anytime.
Now that we have a general understanding of MIPS at a high level for next year, let’s look at some details.
Category Details
Thankfully, little has changed within each category for 2023. For example, the data completeness requirement remains at 70 percent for quality category reporting, meaning clinicians will need to report on 70 percent of each measure’s eligible population to be counted. The big news is that a widely reported quality measure will be retired. MIPS 76 (Prevention of Central Venous Catheter – Related Bloodstream Infections) is no longer an eligible measure because most clinicians were compliant and therefore didn’t differentiate “good” providers from “bad” providers. Additionally, several Improvement Activities were retired for 2023, but this may not have a material effect on anesthesia providers due to some other changes within the program.
For those who are a little more interested in some of the details, the three-point floor for measures without a benchmark has been removed. This served as a point floor for any providers reporting QCDR measures that were not widely adopted in the industry; but, again, this will not likely have an effect on any anesthesia providers moving forward.
The one other detail important for anesthesia providers is to confirm your Non-Patient Facing status with CMS. This status exempts anesthesia clinicians from reporting the Promoting Interoperability category, which is the old “Meaningful Use” program. The reason this is important for 2023 is that CMS will not automatically exclude CRNAs with this status; and, if you are identified as a patient-facing clinician, we need to review this special situation. We will be proactively checking your status; but, to confirm your own status, click here.
Lastly, CMS has finalized the 2023 measures but has not yet published them. CMS has advised the publication date could be as late as January 1, 2023. Hopefully, they will allow registries to make them available earlier. Stay tuned!
If all of this seems a little overwhelming, I have great news and a solution for you. It is called the MIPS Value Pathways (MVP).
MIPS Value Pathways
To simplify the entire process of reporting measures to CMS, the creation and use of an MVP for anesthesia is available next year. The MVP bundles a set of measures to report rather than burden providers to choose. For 2023, the compliance requirement for an MVP is to report four quality measures to include an outcome measure and two medium-weighted or one high-weighted improvement activity. The only catch to an MVP is that you must proactively register between April 1, 2023 and November 30, 2023, which we can do on your behalf.
The measures to choose from are as follows:
Quality (Choose 4)
- #404: Anesthesiology Smoking Abstinence
- #424: Perioperative Temperature Management
- #430: Prevention of Post-Operative Nausea and Vomiting (PONY) – Combination Therapy
- #463: Prevention of Post-Operative Vomiting (POV)- Combination Therapy (Pediatrics)
- #477: Multimodal Pain Management (MIPS CQMs Specifications)
- AQI48: Patient-Reported Experience with Anesthesia
- AQI69: Intraoperative Antibiotic Redosing
Improvement Activities (2 Medium or 1 High)
- IA_BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings – High
- IA_BE_22: Improved practices that engage patients pre-visit – Medium
- IA_BMH_2: Tobacco use – Medium
- IA_CC_2: Implementation of improvements that contribute to more timely communication of test results – Medium
- IA_CC_15: PSH Care Coordination – High
- IA_CC_19: Tracking of clinician’s relationship to and responsibility for a patient by reporting MACRA patient relationship codes – High
- IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Records – High
- IA_PSPA_1: Participation in an AHRQ-listed patient safety organization – Medium
- IA_PSPA_7: Use of QCDR data for ongoing practice assessment and improvements – Medium
- IA_PSPA_16: Use of decision support and standardized treatment protocols – Medium
- IA_PSPA_20: Leadership engagement in regular guidance and demonstrated commitment for implementing practice improvement changes – Medium
To illustrate how this works, we can automatically continue to report on your relationship codes through billing operations (measure IA_CC_19), and you can choose to report the following four quality measures to be fully compliant next year.
- #424: Perioperative Temperature Management
- #430: Prevention of Post-Operative Nausea and Vomiting (PONV)
- #463: Prevention of Post-Operative Vomiting (POV)- Combination Therapy (Pediatrics)
- #477: Multimodal Pain Management
This is the easiest way to meet compliance in 2023; but, if you are interested in learning more about this program, you can review the CMS website.
Schedule a free financial health checkup with Coronis Health to learn more.