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Quick Conversation: Deep Dive Into Navigating The 2025 CMS Quality Payment Program Final Rule

November 20, 2024

Unlock the intricacies of the 2025 CMS final ruling on the Quality Payment Program with insights from Aaron Higgins of Strategic Healthcare Partners. Get ahead of the curve with the crucial performance threshold of 75 points needed to dodge penalties and the revamped scoring system allowing up to 10 points for full compliance on topped-out measures. As the MIPS program evolves into the more streamlined and specialty-specific MIPS Value Pathways, discover how this shift can benefit your practice with the introduction of new MVPs and modifications, especially in cancer and heart disease care. Through our conversation, you’ll gain clarity on the 75% data completeness requirements extending through 2028, the addition of seven new quality measures, and the removal of ten measures, providing a comprehensive view of the changes that await healthcare professionals.

As we close the episode, we shine a light on the collective efforts of our committed team behind “Beyond the Stethoscope: Vital Conversations with SHP.” Experience the meticulous work of our executive producers, Mike Scribner and John Crew, our editor, Nyla Weave, and our social media strategist, Jeremy Miller. Discover our transcription process that blends cutting-edge technology with human expertise to bring precision to every episode. Don’t miss out on delving deeper into our podcast archives at shpllc.com/podcast, and join the ongoing conversation by connecting with us on Facebook and LinkedIn. We invite your questions and comments to further enrich our discussions and explore the ever-evolving landscape of healthcare together.

Guest: Jason Crosby, VP Network Integration & Strategic Planning

Jason currently serves as the Vice President of Strategic Planning & Network Integration for Strategic Healthcare Partners (SHP) of Savannah, GA, with whom he has been employed for 13 years. With SHP, he oversees the Clinically Integrated Network activity, as well as the Business Development and Strategic Planning function.

Prior to joining SHP, Jason served as Finance Director for Georgia Emergency Associates, Decision Support Manager at Memorial Health, and as a Finance Lead with Gulfstream Aerospace.

Guest: Aaron Higgins, Data Manager & IT Strategist

Aaron Higgins has worked with SHP since 2019 as the Data Manager and all around Quality Payment Program expert. In 2021, his role expanded to include IT Strategy to help SHP navigate the changing IT landscape in a post-COVID workplace.

Prior to working at SHP, Aaron worked in various private practices starting in 2008, where he typically held dual roles as both the Health IT Administrator and Meaningful Use/PQRS Manager, and in 2015 he moved to the Savannah area to oversee the Quality Payment Program for a private practice.

Every year, since coming to SHP, Aaron has provided a webinar series updating QPP eligible practices on the proposed & final rule changes coming to QPP (recordings of which can be found on the SHP website).

Transcript

Jason: 

Hello, it’s Jason Crosby with SHP. Welcome to another episode of Beyond the Stethoscope Vital Conversations with SHP. Today we have a quick conversation with our very own Aaron Higgins, who’s going to recap some of the highlights from the recent 2025 final ruling that just came out Opportunity wording. There being quick conversation. If you know Aaron, he can kind of go on and on, but he’s going to give it a shot. How are you doing, aaron?

Aaron: 

I’m pretty good, and I resemble that remark, jason, most certainly. Yeah, so every year at the end of the year, everybody gets excited because something big and fat will drop into our laps every, every Thanksgiving, and that is not Santa Claus, it’s the QPP final rule. Well, it’s bundled into all of the CMS final rules for the year Starting the next calendar years of 2025. Every year there’s always changes to MIPS, to the quality payment program overall, and kind of one of the bigger shifts that we’ve seen the last couple of years is that CMS has really just started to call it all QPP, because they do all these other changes, not just MIPS. But every year we’ve done some kind of big podcast or show and tell about the changes. Well, this year we’re going to try it a little bit different. So, yes, challenge accepted, jason. I’m going to try to keep this very short and just the highlights, and in our show notes we will link to all the sources for this so you can go dive deeper if you need to. Okay, so I think the biggest thing that folks need to be aware of is that CMS is really sticking to that performance threshold. So that performance threshold means you need to score 75 points or greater to avoid penalty. If you score exactly 75 points, you get zero. So you don’t get a penalty. You don’t get any sort of reward.

Aaron: 

75 points is still the goal To aid in that, because some people are still struggling, particularly with some specialty types, really finding good measures. They are changing the way measures get topped out. So previously, measures that were topped out because everybody was doing it were only earning you three points in the quality category and that made it really challenging. You would have to submit a whole lot more measures to get to your full quality. So now it’s scaled. The details of that scaling is in the document that we’re going to link to in the show notes. It’s kind of complicated. You have to go and look at it. You can now earn up to 10 points but you have to earn 100% on those measures. So if you do participate in a topped out measure, you can get more points. That’s good. It’s going to help you with your hitting your overall performance threshold of 75 points.

Aaron: 

Overall Data completeness also isn’t changing there. What data completeness means is the percentage of patients seen, and you recorded their data, regardless of what type of patient it is, and they have that set at 75%. They are maintaining that through 2028. They had talked about 100% and they’ve scaled that back down to 75%. Managed care contracting does not have to be a hassle, and they’ve scaled that back down to 75%. Managed care contracting does not have to be a hassle. At Strategic Healthcare Partners, we specialize in negotiating and managing contracts with payers, ensuring you receive your fair reimbursement for the services you provide. Don’t get shortchanged. Let SHP handle the tough negotiations so you can focus on your patients. Learn more at shplccom.

Jason: 

Another topic that continuously comes up every year with us are MVPs right? So what new ones are coming out for the 25 performance period? And then what changes have been made to existing MVPs? Aaron, yeah.

Aaron: 

So the MVPs, the MIPS value pathways is the way the whole MIPS program is evolving. By 2028, so three years from now everybody will be moving from what’s called traditional MIPS over to the MVPs. To facilitate that, cms is rolling out new MVPs. Now, mvps all slightly differ from each other, but they’re essentially four quality measures that you have to do promoting interoperability, what they are calling a population health measure, and then the cost measures that are associated with your specialty. The nice thing about the MVPs is that it takes away the huge smorgasbord of options that can be overwhelming to a practice. They’re also scaled appropriately for a practice of different sizes so 15 or fewer clinicians, so small practices and that sort of thing. So they are introducing some new MVPs. Again, all of this will be linked in the show notes. They’re also making some modification to the existing MVPs, such as advancing cancer care and advancing care for heart disease. They’ve gone back and they’ve retooled some of those metrics within.

Aaron: 

So if you’ve done an MVP in the past or are interested in doing that, getting away from the traditional MIPS line I highly recommend taking a look at the MVPs for 2025. You have until late 2025 to decide between the two of them. But even then there’s a little catch. They are now allowing you to submit both traditional MIPS and MVPs in your transition year, and then they will give you your score based off of which one performs better. So if you want to go to all that extra effort, you can. Unless you’re a large practice, I don’t see a lot of benefit for it To piggyback adding and revising of measures.

Jason: 

Tell us what new quality measures have been added and those that have been removed for 25, and then what changes have been made to existing ones as well.

Aaron: 

Yeah. So we have seven new quality measures. They are all mostly focused around chemotherapy. Unless you’re in the chemotherapy world, the cancer world, these measures aren’t probably going to apply to you. They have removed 10 measures Again. All these are going to be in the show notes.

Aaron: 

This is a quick conversation, I’m not going to dive into them. And they have made a substantive change to 66 of them. So, just like every year, if you’ve already picked your measures, you’re really comfortable with these. You’re doing well at them. Go back and make sure they haven’t been changed. Sometimes they’ve substantively changed some very popular measures and people who are doing well one year are doing terrible the next.

Aaron: 

Looking at some of these changes, they’re for the better and should help you perform better in those measures and kind of pivoting on the measures is improvement activities. Now, the changes they’ve made to improvement activities. They’ve introduced two new ones, they’ve modified one and then they have removed a total of four. Now those four that they have removed are actually very popular. In fact, one of them is extremely popular and that is the availability of your EHR 24-7-365.

Aaron: 

The reason why CMS removed it is because, a everybody was doing it and B it was too easy. Essentially, if you have remote access to your EHR and let’s be honest, who doesn’t these days you could qualify for saying you did this improvement activity. Cms knows this and so they’ve removed it. So if you were banking on this improvement activity, I’m sorry you’re going to have to change it up for next year. But another thing too, with the improvement activity is just to kind of pivot. They’ve done away with the medium and high weighting. Now if you are a small practice so 15 or fewer clinicians you only have to pick one improvement activity. If you are not a small practice, you have to pick two. Now there’s some other criteria too that allow you to pick one. If you qualify for that, take a look again in the show notes.

Jason: 

All right, shifting gears, reporting of the electronic clinical measures. How will the new complex organization adjustment affect the APM entities, virtual groups and such?

Aaron: 

Well, first off, cms knows that complex patients are more expensive. They also have seen a trend amongst ACOs and other advanced payment models shedding their specialty groups because their specialty groups were dragging down the average score. Cms doesn’t like that. They see a problem with it, so they are adjusting the scoring. Talk to your APM, see how will the changes to scoring affect their decisions going forward. But this will be for the 2027 year. So even though the performance year is 25, there’s not any benefits seen until 2027. So that still may make some APMs want to shed some of their specialties out of that, and we’ve seen that, jason. We’ve seen some bigger ACOs dropping specialties altogether and CMS is trying to stem the tide of that.

Jason: 

Yeah, that makes sense. You know, when QPP first started out, cost was that sort of gray area folks weren’t sure about. So what changes have been made to the cost measure scoring methodology for the 24 period?

Aaron: 

Well, it is still a mystery wrapped in an enigma. The cost category is receiving some changes. Again, cms is revising their methodologies, adjusting the formulas a little bit, making it a little easier for practices to achieve, because they know it’s one of those things that’s completely out of the practices control 95% of the time. So they are making some adjustments there based off of feedback that they’ve received as well as the performance that they’ve done in the past. So they’re also introducing some new measures over there. So hopefully that will make it easier for practices to achieve the cost measures.

Jason: 

You know what. We’ve kind of run up on time. We call this a quick conversation for a reason. Aaron, you did a fantastic job. I got to say I’m impressed. That’s probably the most condensed conversation we have ever had, but impressive but awesome info, as usual. And to our listeners. As Aaron said at the beginning, we’ll put a bunch of information in the show notes. You’ll find everything you need there and you know how to find us. If you need any QPP info, don’t contact me, contact aaron. You’ll find all our info on shplccom. Aaron, thanks for the uh quick conversation. Hey, you too. We’ll talk to you later.

Aaron: 

All right, bye-bye this has been an episode of beyond the Stethoscope Vital Conversations with SHP. Your hosts today have been me, aaron Higgins.

Jason: 

And me, jason Crosby. This is a production of Strategic Healthcare Partners. Our executive producers are Mike Scribner and John Crew, our editor is Nyla Wiebe and our social media manager is Jeremy Miller, with Boost by Design, transcription by a robot and tweaked by me, a human, jason.

Aaron: 

Crosby, you can visit our podcast archive on our website shplccom slash podcast, and there you can learn more about the services and products offered by SHP.

Jason: 

You can also find us on social media, including Facebook and LinkedIn, where you can send us questions and even leave comments about this episode.

Aaron: 

Thank you.

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