January 10, 2024
The Centers for Medicare & Medicaid Services (CMS) finalized several updates to the participation requirements for the year 8 of the Quality Payment Program (QPP) as part of the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) released November 2, 2023. This article highlights the finalized QPP policies that are most relevant to surgeons.
The QPP comprises two participation tracks; clinicians can report via the Merit-Based Incentive Payment System (MIPS) or participate in an Advanced Alternative Payment Model (APM). Under MIPS, clinicians are scored based on four categoriesāQuality, Cost, Improvement Activities (IA), and Promoting Interoperability (PI)āthat each contribute a specific weight to their final MIPS score. MIPS eligible clinicians who participate in the program in 2024 will receive a positive, neutral, or negative payment adjustment to their 2026 Medicare Part B payments, based on 2024 performance.
In contrast, qualifying participants (QPs) in an Advanced APM, which are clinicians who meet participation thresholds based on Medicare payments or Medicare patients seen through an APM, will receive a higher physician fee schedule base conversion factor update (0.75%) compared to non-QPs (0.25%), starting with the 2024 performance year/2026 payment year.
Surgeons can report individually or as part of a group, subgroup, or APM Entity. However, due to the workforce shift away from private practice toward employed surgery, an increasing percentage of surgeons participate in the QPP through their employer. Because QPP performance is tied to Medicare payment adjustments regardless of employment status, surgeons should keep track of their performance within the program and understand how it might influence compensation within their group or institution. Surgeons can determine QPP eligibility for performance year 2024 by searching the .
MIPS eligible clinicians may also choose to participate through a MIPS Value Pathway (MVP)āan alternative reporting pathway to traditional MIPS. Whether surgeons participate via traditional MIPS or an MVP, their score will continue to be calculated based on the four performance categories.Ģż
MVPs were first available for voluntary reporting in the CY 2023 performance period. An MVP includes a subset of measures and activities across the quality, IA, and cost performance categories focused on specific specialties, conditions, or patient populations. Each MVP also includes a foundational layer that includes population health measures, as well as all PI performance category measures.
If a surgeon chooses to participate in an MVP, he or she must register to participate in this pathway and select quality measures and IAs from the MVP to report. CMS automatically calculates the cost and population health measures associated with the MVP using administrative claims measures. A clinician or group is only scored on these measures if enough patients are attributed under each measure (similar to traditional MIPS). For the 2024 performance year, clinicians can choose from 16 MVPs as shown in Figure 1 below.
MVP scoring generally aligns with traditional MIPS. The performance category weights will remain consistent with what has been finalized for MIPS in 2024. The MIPS reweighting policies will also be applied to MVPs.Ģż
Multispecialty groups can create subgroups to report MVP performance information relevant to specific specialists or care teams within the larger group (also referred to as the affiliate group) so that participation is more tailored to the care they deliver, such as clinicians who provide cancer care or joint repair. Subgroup reporting is currently voluntary for MVP participants; however, beginning in 2026, multispecialty groups will be required to form subgroups to report MVPs. CMS uses the initial 12-month segment of the 24-month MIPs determination period to determine the eligibility of clinicians intending to participate and register as a subgroup.
For more information about available MVPs, MVP reporting, and subgroup reporting in CY 2024, visit the Āé¶¹“«Ć½QPP Resource Center and/or the .
Many MIPS scoring policiesāwhich apply to both traditional MIPS and the MVP frameworkāremain the same in 2024. This year, the performance threshold, or the number of overall MIPS points required to avoid a payment penalty for the 2026 payment year, remains at 75 points.
The performance category weights also are unchanged. In general, quality and cost both contribute 30% to the MIPS overall score, PI contributes 25%, and IA remains at 15% (see Figure 2). However, note that there are specific scenarios that could trigger the redistribution of these weights. () Surgeons should refer to the Āé¶¹“«Ć½QPP resources for more details about the 2024 MIPS policies.
The Quality category aims to measure the quality of care provided. For the CY 2024 performance year, the data completeness threshold will increase to 75%. This means a provider must report 75% of their total cases for applicable patients to fully report the quality performance category.
For the CY 2024 performance period, surgeons can choose from 198 clinical quality measures (CQMs), as well as numerous measures offered through Qualified Clinical Data Registries (QCDRs). Participants can explore the .
The PI category focuses on how clinicians use certified electronic health record technology (CEHRT) to manage patient engagement and the electronic exchange of health information. To receive a score in this category, use of CEHRT is required.
Updates to PI reporting requirements in 2024 include:
The cost performance category aims to evaluate a clinicianās total cost of care during the year, a hospital stay, or a specific episode of care for attributed patients. CMS calculates the cost performance category based on claims data. There are no individual reporting requirements for cost. Clinicians who demonstrate improvement in the cost performance category from one performance period to the next are eligible for a cost improvement score; this will be calculated at the performance category level rather than the individual measure level starting in 2023. CMS continues to add episode-based cost measures to the cost measure inventory. Surgeons can explore on the CMS website.
Clinicians who receive a substantial portion of their reimbursement or see a substantial number of patients under what CMS designates as an Advanced APM are considered QPs. Advanced APMs bear a certain amount of risk determined by CMS, and all Advanced APM participants must now use CEHRT. In 2024, the payment and patient thresholds to qualify as a QP increased, making it more challenging for clinicians to qualify for this track of the QPP. The incentive policy for Advanced APM participants also changes beginning in CY 2024; rather than a lump-sum incentive payment (5% historically, 3.5% related to 2023 eligibility), QPs will receive a higher MPFS base conversion factor update than non-QPs (0.75% vs. 0.25%) going forward.
For more information about , visit the CMS QPP website.
In recent years, the Āé¶¹“«Ć½has focused advocacy efforts on the need to reframe the QPP to focus on patient goals, help patients determine where to find the best care for their needs, support the programmatic nature of modern care delivery, and drive quality improvement cycles. In the CY 2024 MPFS proposed rule, CMS discussed its Ģżand sought feedback on how it could modify QPP policies to better align with those goals.
In response, the Āé¶¹“«Ć½raised concerns that current measures focus on single instances or services delivered in care, which perpetuates care silos created by fee-for-service. This approach detracts from centering care around the patient, pits members of the care team against each other rather than incentivizing integrated care, and wastes resources, among other issues. The College suggested that, in order to resolve these issues, CMS must refocus on the patient and encouraged CMS to rethink how to build a patient-centered quality program that reflects care delivered in a service line while valuing what matters to the patient and create incentives for the team to organize around the patient to deliver on patient goals.
The Āé¶¹“«Ć½provides examples of successful programmatic approaches to quality, including Āé¶¹“«Ć½Trauma Verification, Commission on Cancer, Childrenās Surgery Verification, Geriatric Surgery Verification, and so on.Ģż
To drive these efforts forward, the Āé¶¹“«Ć½has developed a new type of measure, a programmatic measure, that incorporates the essential elements of the Āé¶¹“«Ć½Quality Framework. Programmatic measures represent a specific clinical program and combine structure, process, and outcomes measures along with improvement activities in hopes of informing patients about the care they seek and driving care teams to improve. The Āé¶¹“«Ć½has submitted programmatic measures to other CMS programs such as the Hospital Inpatient Quality Reporting Program and the Bundled Payments for Care Improvement Advanced model.
The ACSās response to the 2024 MPFS proposed rule can be found on the Āé¶¹“«Ć½website.
Kate Murphy is a Regulatory and Quality Assistant, Haley Jeffcoat is a Quality Affairs Associate, and Jill Sage is Chief of Quality Affairs in the Āé¶¹“«Ć½Division of Advocacy and Health Policy in Washington, DC.