Navigating CMS Quality Payment Program Changes: Mastering 2024 Modification with Jason Crosby and Aaron Higgins - Part 1

We'll talk all about the changes that practices should participate in traditional MIPS , alternative payment models and the MIPS value pathways . There should be a little something for everyone who participates in the quality program . Are you ready for this vital conversation ? Let's get started .

Instead , I'll be interviewing Aaron to discuss the latest changes to the Quality Payment Program , or QPP , of which the MIPS program is housed . Before we get started , Aaron , tell our audience a little bit about yourself and why QPP of all things .

So I was working for a healthcare practice as their general around IT , which also meant that I took care of the EHR they were using , and it kind of grew from there both the programs and my responsibility and learning about how those programs work . So I've seen the programs morph and change .

Of course we had meaningful use , which I think a lot of people still have PTSD just with that name and that of course , changed into the MIPS program , which is under the umbrella of the QPP program , the Quality Payment Program . I know QPP program is like saying ATM machine , but that's where that lives .

So I became passionate about quality because , as the IT guy , I could see the importance of getting the right data , because the right data ultimately leads to better understanding your patient population and then , from there , better patient outcomes , or at least that's how it's supposed to work .

I know in practicality that's not always the case , but quality has always been a passion of mine , ever , since Makes sense .

Finally , but early in the year , cms , as they usually do , had released a proposed ruling that had many in the industry obviously talking . So what were some of the changes that were proposed that didn't quite make this final cut ?

They genuinely do want to hear from people , because they otherwise are operating in a vacuum . They release a proposed rule I think it was back in July and open up comments and then close the comments and then came out with the final rule . Now CMS is allowed to sometimes drop a final rule that has things in it that weren't at all in the proposed rule .

We didn't see that this time , which was refreshing that they didn't do that , because that's always been a mind boggler . Some of the things that are staying or not staying from the proposed rule to the final rule is they were going to raise the point minimum .

That had everybody freaking out because it probably would have meant that you would have needed to get about 90 points to avoid penalty . They're going to keep it at 75 . There's a lot of feedback on that . They did say they want to get to a higher number . So 2024 may be the last year that we see it at 75 .

It's been at 75 this year and last year We'll see that . The other one was data-completedness . They were saying 100 percent , so that means 100 percent of patients seen . That was in the proposed rule . They're rolling it back and they're keeping it at 75 percent . That should be good enough .

You know , sometimes patients are seen in a different system or there's a need to have them on a paper chart and that 100 percent completeness was going to be potentially impossible . They didn't indicate that they're going to go any higher than that right away .

2026 is when they're going to reevaluate it , so we have a few more years at least before they consider changing the completeness threshold . All right .

So I see it being raised like 85 , maybe even 90 percent , but never 100 .

So they're keeping them the same , they're not rebalancing and , of course , if you are exempt from a category like some people might be exempt from promoting interoperability they will divide up that remainder percentage amongst the other categories .

But quality and cost remain at 30 percent of your total score , improvement activities 15 percent and promoting interoperability worth 25 percent of the final score .

Quality ID 111 , which is pneumococcal vaccine status for older adults . Quality ID 128 , we'll get back to this one here in a second , that's the BMI screening . And quality ID 402 , tobacco use and help with quitting among adolescents . So 110 and 111 kind of got rolled up into a more major , a newer measure that's all about immunizations of all types .

So they felt that those were redundant so they removed those . The BMI screening was considered topped out and I know , if I had to guess , 90 , if not close to 100% of our listeners who participate in QPP probably do this measure . It's very easy and that's why CMS is removing it from traditional MIPS .

It still will live on in the MVP program , which we'll cover here in a little bit , but it's more or less it's gone .

So if you're relying on this as one of your six measures that report to CMS for QPP , you won't be able to report in 2024 unless you're participating in an MVP , and if you're not enrolled in one by the time you hear this , it's too late , so we'll get onto that here in a second . And then tobacco use .

What they're doing is they're actually changing another measure to include adolescents as a part of the patient population . So instead of having one for adults and one for kids , they're just having one tobacco measure . So that's why that one's going away , and that measure that they're folding it into is quality ID 226 .

So if you are already reporting 226 , again a lot of practices are . This now covers anybody age 12 and above instead of age 18 and above . And then , finally , they're changing quality ID 398 , optimal asthma control to also include nursing home residents , who were strangely excluded from past measures .

So you'd start halfway through April and then 90 days out from there Whatever was best reflective of your promoting interoperability and gave you the higher score . They're now changing it . Cms has talked about wanting to do a full year . They didn't propose that , they just talked about it .

They did propose and it did go through that they're going to do 180 day continuous reporting periods . So now that's six months of promoting interoperability time window that you have to report on . Now again , it can be any continuous 180 days . Again , you could do it in the middle of April , as long as it's a continuous 180 days . So just be mindful of that .

The window to get your house in order with promoting interoperability is going to close very quickly . If you haven't started promoting interoperability by the start of June , you're gonna be in trouble .

Another change is there was an optional measure in promoting interoperability called Safer Guidelines . That's no longer optional . You have to say that you do or you don't . It's a yes or no . If you don't , you fail promoting interoperability . So check out Safer , that's S-A-F-E-R guide and again you have to be a testing to that . So that's a yes or no .

And there are also some changes to the PDMP . So that's the opioid query . So the PDMP now measure excludes those who do not prescribe any schedule two opioids or schedule three or four during the performance period .

So if you have a mid-level provider , for example , that doesn't script any opioids at all , or you have a doctor who doesn't script any opioids , they can be exempted from that measure . So if they're scoring a zero and they don't script any of these , then that's fine , they can be exempted from it .

Now the whole category will be automatically reweighted to zero for clinical social workers and any non-patient facing clinicians , groups or virtual groups . But going forward , physical therapists , occupational therapists , qualified speech language pathologists , qualified audiologists , clinical psychologists and registered dieticians will now have to do promoting interoperability .

They will no longer be exempt from it . So that's important for those type of providers to be aware that they are going to have to do promoting interoperability . If they're not sure what promoting interoperability is , they have about 30 days to learn .

So pay attention there All right . Now on to the last one IA improvement activities . What should folks be aware of ? Any changes there ?

It should be fairly easy for someone to do their improvement activities . Those are attestations , those are yes or no , and then you have to have proof that you've done them . Don't just say you've done one , not saying that . Make sure you have the proper documentation . But odds are you're doing something in the improvement activities that would qualify .

The population health tools , for example , can start to give you some insight into what your cost category might be , but it's not perfect . So yeah , that being said , cms is fine-tuning the calculations .

They have been immediately far too mean with their score and so they've gone in and they've made some changes to the maths behind the scenes , and so it should be more fair . We'll see

. I'll take that one with a grain of salt . Like I said , I'm not a fan of cost . It's kind of annoying that you don't really know what's going on until it's too late . But CMS continues to broaden the cost category and they have five new episode-based measures and they removed one of them .

The one that they removed was simple pneumonia with hospitalization , and they did that because there's been coding changes and they didn't feel that they could accurately track that one anymore . So it goes away , little aside and kind of pivoting to our next section . Here is the cost category , and the MVPs is a lot nicer .

In the last few years , if you guys have listened to our podcast that Aaron and I did last year or previous webinars , you've heard Aaron talk about MIPS Value Pathways Program or , as our good friends at CMS call it , the MVP program .

Not sure how much valuable player that could be , but once you start from beginning , Aaron , tell us a little bit about that program .

So it was about four years ago now that we first were really introduced to the MIPS , value Pathways or MVPs , and they were designed for those in traditional MIPS who weren't a part of an ACO or some kind of alternative payment model APM and so they , being CMS , felt that it was too much of a smorgasbord . There were too many options available for a practice .

It was very overwhelming . So they created the MVPs to help practices have less of an administrative burden . That was their goal in all of us , and they've started to incentivize people to participate in the MVP program early , because eventually it's going to be required and we'll get to that here in a second .

But they're building the MVPs around certain areas of medicine , not specialties , particular areas of medicine . So , for example , there's the advancing care for heart disease , optimizing chronic disease management and promoting wellness .

So that way those who are doing similar types of medicine not necessarily the same specialty , who are seeing a lot of the same patients , can be graded against one another in the same cohort . So right now , if you will go back to measure 128 , if you're doing measure 128 , you're compared against pretty much the whole country .

How are they doing with that measure ? But instead in the MVP that list is shrunk down to a handful of measures and you're only graded against those in your cohort , your MVP , who actually also pick those measures . So it should give a better picture of how the quality measures are working out .

Mvps will need to be picked in the year prior to participation and so , again , by the time you're hearing this , the window is closed . It closes November 30 , which for us , is two days away and for you all who are listening , was about eight days ago . So windows close .

Sorry , you won't be able to participate in MVPs this year , but start looking at them and start planning for 2025 . Because , with the looming stick , you might as well go for the carrot , and I think there's a lot of wins .

So , while you're not getting any bonus incentive payment and we'll cover that here in a second you are going to have less an administrative burden .

Then there's the optimizing chronic disease management , which is good for cardiologists , internal medicine and family medicine . So there's a lot of options . So if you are a cardiologist , you may have three or four MVPs to pick from and then from inside there you can fine tune what measures you're looking at .

So depending on what sort of cardiologist you are and what sort of focus you have in your practice , you may find one MVP being better than another , whereas a different practice in a different part of the country may find a slightly different MVP good for them .