Newly proposed policies are issued for the Quality Payment Program (QPP) by The Centers for Medicare & Medicaid Services (CMS) through the Medicare Physician Fee Schedule (PFS) Proposed Rule for the 2023 performance year and years after that, until further changes. These newly proposed policies include proposals regarding Advanced Alternative Payment Models (APMs), Merit-based Incentive Payment System (MIPS), and public reporting of QPP data on Care Compare, as well as multiple requests for information (RFIs).
We’re focusing our proposals on refining the subgroup participation option and also continuing to develop new MIPS Value Pathways (MVPs). Minimal changes are also proposed for traditional MIPS so that it can provide clinicians continuity and consistency till they start being familiar with MVPs.
2023 Policy Highlights
Key QPP policies proposed in the 2023 PFS Proposed Rule are mentioned below:
MVPs
Revising 7 formerly established MVPs for reporting and introducing 5 new MVPs, starting in 2023 performance year.
When reporting as a subgroup, calculate administrative claims measures at the affiliated group Taxpayer Identification Number (TIN) level (of the affiliate group).
Traditional MIPS
Continuing to use the mean final score from the 2017 performance year to establish the performance threshold for the 2023 performance year (the performance threshold would be 75 points).
Continuing to use the mean final score from the 2019 payment year to establish the performance threshold for the 2025 payment year (the performance threshold would be 75 points).
For the 2024 and 2025 performance years, increasing the data completeness threshold to 75%
Updating MIPS improvement activities inventory and quality measures and by:
Expanding the “high priority measure” definition to include health equity-related quality measures.
Decreasing 6 quality measures and reducing them from 200 to 194 by removing 15 and adding 9 MIPS quality measures.
Regulating language related to equity and standardizing it.
Changing improvement activities by modifying 5 existing improvement activities, adding 4 new improvement activities, and removing 6 of the existing improvement activities.
Making changes in measure reporting requirements for the Promoting Interoperability performance category and making a proposal to make the Query of Prescription Drug Monitoring Program (PDMP), a required measure, starting with the 2023 performance year
Allowing APM Entities to report Promoting Interoperability at the APM Entity level
Establishing a maximum cost improvement score of 1% point out of 100% points for the cost performance category, beginning with the 2022 performance period
Advanced APMs
Making 8% minimum permanent for the Generally Applicable Nominal Risk standard for Advanced APMs
Further details regarding comment period of 2023 PFS Proposed Rule will be coming soon.
For More Information
Learn more about the 2023 PFS Notice of Proposed Rulemaking and the QPP proposals from the following resources:
Press Release – Provides further details about the proposed policies for QPP as well as other CMS initiatives.
2023 QPP Proposed Rule Resources:
2023 Overview Fact Sheet – Outlines proposed revisions to QPP and lists the 2023 PFS Proposed Rule RFIs.
2023 Policy Comparison Table – Highlights the changes to QPP policies proposed in the 2023 PFS Proposed Rule and compares them to the finalized 2022 policies.
2023 MVP Proposals Table – Showcases the proposed MVP policy changes, beginning with the 2023 performance year.