MIPS: Succeed in 2023

Did you know? In 2023 you need to earn 75 points to avoid the 9% penalty completely. While not all clinicians and groups will meet the minimum threshold, starting early and earning as many points as possible will help mitigate the potential for a negative adjustment and maximize your success.

While MIPS is indeed getting harder every year, Mingle Health is here to guide you to success.

Meet with your Mingle Consultant to learn all that you need to know, set goals, and create a project plan to participate in all categories of MIPS. Be sure to share important deadlines and milestones with stakeholders in your organization such as clinicians, billing team, and anyone else who assists with quality management efforts.

Mingle Health is dedicated to helping you succeed with MIPS and we are proud to have been recognized as a top performer by KLAS for Quality Management.

What can you expect from your assigned Consultant?

When you work with Mingle Health, you gain access to unmatched MIPS expertise in your assigned Consultant. Your consultant can provide a framework for your MIPS project, offer recommendations, and answer any specific questions you may have.

Your consultant will review your MIPS project progress at regular intervals to facilitate the work you’re doing in the Mingle Health Dashboard and assist when necessary.

What will your consultant expect from you?

To ensure your MIPS project progresses through the year, you’ll need to upload your data to the Mingle Health Dashboard in a regular cadence. You’ll need to set up a MIPS workflow in your organization to make sure you’re not falling behind throughout the year.

You and your team will serve as the champions for your practice improvement. Due to the remote nature of our work, your team should be familiar with attending online meetings and be able to use e-mail, Excel, and our web-based software.

Your team will need to coordinate with internal system vendors such as EHRs and billing systems. Team members will ensure that all necessary files will be provided according to Mingle specifications (see resources below).

Your team will be essential in helping to spark engagement and excitement for your entire clinical and operational staff.

How often will you meet?

Our goal is to be a partner of your practice, helping to navigate challenges and maintain steady progress along the way.

You’ll have access to your Consultant via email, through our website’s chat functionality, or you can give us a call. You can request a meeting with your Consultant when you have specific questions about your MIPS project or if you run into challenges that require your Consultant’s expertise.

Our goal is to support your organization in earning the highest MIPS score possible and maximize the ROI for participation. When you work with Mingle, not only do we help you avoid the 9% penalty, we pair you with a knowledgeable and friendly Mingle Health “coach” to guide you every step of the way through the program.

Completing the actions by the dates listed below gives you the best chance of driving your practice quality toward your goals and gives the greatest visibility for monitoring your MIPS score.

If you have begun working with us after some of these dates have passed, we will assess together how to best mitigate the risks to your MIPS reporting.

Here are additional resources to assist you with MIPS and the QPP:

• QPP Eligibility Look Up Tool
• Video: The Mingle Health Expert Guide to the 2023 Final Rule
• Quality Reporting: Numerator Data Specifications & Requirements
• Quality Reporting: Denominator Data Specifications & Requirements
• Supported Data Formats
• The Mingle Health Blog

New to MIPS? Have questions?

We’re here to help. Please reach out to your Consultant or use the live chat to ask your questions. You can also call M-F 9am – 5pm ET: 866-359-4458

Analyzing your past performance is one of the best ways to understand how you are scoring under MIPS.

Take a moment to pull together prior reports and data to understand what worked well and areas for improvement including data capture, workflows, and EHR vendor requirements.

Make sure to download your most recent CMS Feedback Report which includes a breakdown of your past MIPS scores, including the MIPS Cost category. CMS typically publishes Feedback Reports for the prior performance year in July.

Questions to ask:

• How did you score in each category?
• Are those scores aligned with your goals?
• What are your areas of strength? What could be improved this year?

Make sure to share your questions, responses, and prior year performance reports with your Mingle Consultant.

MIPS continues to increase in difficulty every year.

Importantly, the threshold to avoid a penalty will stay at 75 points for 2023. This means that it’s still tough to avoid the 9% penalty under MIPS.

Because MIPS is getting harder, we advise our clients to monitor their MIPS performance throughout the year. This means estimating your scores at least quarterly so you have the opportunity to spot gaps and areas for improvement and make changes before the end of the year.

Scoring as high as possible will help you mitigate the potential for a negative payment adjustment. You’ll receive the maximum 9% penalty if you fail to participate but were MIPS eligible and didn’t receive an exclusion.

Here’s a summary of changes for the program this year:

Quality

• Quality continues to be worth 30% of your total 2023 MIPS score
• Data completeness remains at 70% for Quality
• CMS has changed seventy-six Quality measures in the 2023 Final Rule. There have also been nine Quality measures added and eleven measures removed.
• The 3-point floor for scoring measures (with some exceptions for small practices) will be removed beginning in performance year 2023

Cost

We’ve created a 15-minute video lesson to help you understand the basics of the Cost Category. You can access the lesson in our resource center, or by clicking this link: Understanding the Cost Category

• Cost is worth 30% of your total 2023 MIPS score
• CMS calculates Cost measures automatically through Administrative Claims
• For 2023, CMS has introduced a 1% improvement score available for MIPS participants who have improved their scoring in the Cost Category from one Performance Year to the next.

Promoting Interoperability

• Promoting Interoperability remains at 25% of your total 2023 MIPS score
• Nurse Practitioners, Physician Assistants, Certified Registered Nurse Anesthetists, and Certified Nurse Specialists will no longer qualify for Automatic Reweighting in the Promoting Interoperability category.

Improvement Activities

• Improvement Activities remain at 15% of your total 2023 MIPS score
• In the 2023 Final Rule, there were four Improvement Activities added, five activities modified, and six activities removed.
• To earn full credit for IA, you generally need to submit one of the following combinations of activities:
  • Two high-weighted activities
  • One high-weighted activity and two medium-weighted activities
  • Or four medium-weighted activities

Click here to download our 2023 MIPS Changes Guide >>

There are no changes to previously eligible clinicians: physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, certified nurse midwives, and social workers. Clinical psychologists and therapists were added in 2019.

You can find more information on how MIPS eligibility is determined on the QPP website >>

For clinicians that fall under the low volume threshold and still want to participate, they can opt in to the MIPS reporting and receive incentive payments based on success within the program.

Clinicians are exempt for any of the following reasons:

• Qualifying participant in an Advanced APM
• Low volume threshold:
  • Treat ≤ 200 Medicare patients
  • OR have ≤ $90,000 in Medicare Part B allowable charges
  • OR provide ≤ 200 Medicare Part B services
• First year provider in Medicare Part B PFS
• Significant Hardship Exemption OR Extreme or Uncontrollable Circumstances (EUC)

CMS updates eligibility and special statuses at two points in the year called the “MIPS determination Periods:”

• 1st Determination Period: 10/1/20 – 9/30/22
• 2nd Determination Period: 10/1/21 – 9/30/23

Visit the CMS NPI Eligibility Look Up Tool here

Dr. Mingle’s highlights from the 2024 Proposed Rule can be found in the video below or in our 2024 Proposed Rule blog post here >>

2024 Proposed Rule | Quick Summary

• CMS has proposed an increase of the MIPS Performance Threshold to 82.
  • That’s an increase of 7 points from the 2023 threshold.
• CMS has proposed increasing the Promoting Interoperability Performance Period to 180 days (up from 90 days).
  • See our Promoting Interoperability section below for more details on PI in the 2024 Proposed Rule.

Improvement Activities

In the 2024 Proposed Rule, CMS has proposed:

• Five new activities “to help fill gaps in the inventory.”
• A modification to one existing activity
  • PSPA_16: Use of decision support & standardized treatment protocols to “explicitly promote the use of clinical decision support (CDS), particularly open-source, freely available, interoperable CDS.”
• And removing three activities “to help ensure the inventory reflects current clinical practice.”
  • PSPA_29: Consulting Appropriate Use Criteria (AUC) Using Clinical Decision Support when Ordering Advanced Diagnostic Imaging is removed due to disbanding the AUC program.

In addition, CMS has proposed one activity focused on MIPS Value Pathways:

• IA_MVP, titled “Practice-wide quality improvement in the MIPS Value Pathways Program (MVP).
  • Requires “a clinician to complete a formal model for quality improvement action that is linked to a minimum of three of the measures within the specific MVP.”
    • Formalizes QI activities leading to improvements in quality of care
    • Fosters a culture of participation by staff.
    • Incentivizes voluntary MVP adoption.
  • Clinicians reporting traditional MIPS are ineligible for this activity.
  • Attestation requires that:
    • The chosen MVP is reported. Registration for an MVP is not enough.
    • Completion of the necessary elements of the activity as per the data validation.

CMS has also stated that they “are not revising group reporting requirements for MVP’s at this time.”

• CMS is applying the group-level requirement to subgroup reporting, which requires 50% of NPI’s billing under the TIN to attest to an activity.
• “If a subgroup consists of 50 percent or more of the clinicians in the affiliated group, and the subgroup attests to completing an activity, then the group would receive credit for this improvement activity as this meets our standard for a group’s completion of an improvement activity specified at § 414.1360.”

Promoting Interoperability

In the 2024 Proposed Rule, CMS has proposed:

• An increase in the PI reporting period to 180 days (up from 90 days).
• A modification to the exclusions for Query of PDMP for providers who don’t electronically prescribe any Schedule II opioids, Schedule III, or Schedule IV drugs during the Performance Period.
• Requiring a “Yes” attestation on the High Priority Practices SAFER guide measure.
• And a continuation of PI reweighting for Clinical Social Workers.
  • Note: In 2024 CMS will no longer re-weight PI for physical therapists, occupational therapists, qualified speech-language pathologists, clinical psychologists, and registered dietitians or nutrition professionals (per the 2023 Final Rule.)