Are you ready to master the CMS Quality Payment Program changes for 2024? Buckle up as we, your co-hosts Jason Crosby and Aaron Higgins, equip you with the necessary knowledge to navigate these changes. We unpack the crucial amendments, including participation in traditional MIPS, alternative payment models, and the MIPS value pathways. We also delve into the changes that didn’t make the cut, and provide an in-depth understanding of the performance expectations for the four categories of QPP: quality, cost, improvement activities, and promoting interoperability.
As the conversation continues, we shed light on the adjustments to the Promoting Interoperability category for the 2020 MIPS reporting period and introduce you to the MIPS Value Pathways Program (MVP). From the removal of the base and performance score to the introduction of the Promoting Interoperability performance score, and the mandatory Safer Guidelines measure, we cover it all. We also discuss the transformations in the Improvement Activities and Cost categories and how MVP influences traditional MIPS participation. Gain insights on how these changes can be strategically navigated for an optimal performance and a reduced administrative burden.
Guest: Jason Crosby, VP Network Integration & Strategic Planning, SHP
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, SHP
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).
When not reading the annual Final Rule or answering questions about QPP, Aaron can be found serving on the board of Family Promise of the Coastal Empire, church committees, and on the Pooler city council. Aaron lives in Pooler, GA with his wife and golden retriever.
Transcript
Speaker 1:
Welcome to Beyond the Stethoscope Vital Conversations with SHB. I’m your co-host, aaron C Higgins. On today’s episode, jason Crosby interviews… well, me. We talk about the final rule that was recently released by CMS for the 2024 Quality Payment Program for QPP. 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.
Speaker 2:
Hey everyone. This is your host for today’s episode, Jason Crosby. Today I’m here with Aaron Higgins, who you all know as my partner in crime, usually with part of the podcast, but today we won’t be discussing the latest news headlines. 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.
Speaker 1:
Well, hey there, jason. Yeah, so I got involved in quality Gosh now I got to date myself, circa 2009, when there is the early days of PQRS and meaningful use. So I was working for a healthcare practice as their ITI, their general around ITI, 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.
Speaker 2:
And just as time has gone it’s just become even more important. I think that you understand those things as we help out our clients, or data polls or the case may be pretty valuable stuff. So let’s kind of jump into it here. The QPP honor roll dropped in November. 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?
Speaker 1:
Yeah, cms does this every year and we see it always with the proposed rules right. They have that whole feedback period and CMS, where their part, actually does listen to all the comments. Not only are they legally required to, but I’ve had personal conversations with some of the higher up folks at CMS. 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.
Speaker 2:
I’m sure in your opinion too, that gives a lot of folks some time to better prepare, both on the provider and platform side, I would imagine.
Speaker 1:
Oh, absolutely yeah, and even with downtime operations, going back and putting those charts into the EHR, that actually is going to become more important. If I had a look at my crystal ball, I don’t think they’re going to raise it to 100. I think a lot of the feedback was focused on that very thing and that it’s almost impossible to get 100. So I see it being raised like 85, maybe even 90 percent, but never 100.
Speaker 2:
Gotcha, gotcha Good stuff. Okay, let’s hit on one of the categories there Performance requirements. What are some of the performance requirements coming in the 24 plan year? And to CMS, change any of the weights.
Speaker 1:
Well, so QPP or MIPS, is comprised of four categories. We have quality, cost, improvement activities and promoting interoperability and how you get to your final scores based off of a percentage of your score overall from these. 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.
Speaker 2:
Consistency. I’m sure helps out the providers as well, not having to deviate each year with those changes. On the quality side, tell us about some of the quality measures and how the proposal suggests removing several or at least changing some of them up.
Speaker 1:
Sure, so every year the quality measures are reevaluated to see are they effective, are people using them, or maybe too many people are using them and they’re considered topped out at that point. So this year we have a handful of removals and that’s four of them Quality ID 110, which is preventative care and screening for influenza immunization. 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.
Speaker 2:
Significant changes with regards to the metric or measure that folks typically track. Some modifications to those. So all right. So we got two of the categories. Now Tell us about PI promoting interoperability. What changes there that folks should be aware of?
Speaker 1:
Well promoting interoperability is. There’s actually a big change there. A lot of folks may not have realized this, but PI was a 90 day reporting period. So three months continuous 90 day reporting period. You could pick any 90 day period you wanted. 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 that practices. 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.
Speaker 2:
Wow, I tell you what. For those ancillary type providers, the OTs, the STs, those folks, that’s a big change to what they’re usually accustomed to. Again, you touched on the four different categories. Listeners keep in mind the PI group is 25 percent, as Aaron mentioned. Some significant changes represent a quarter of that overall score. So pay attention there All right. Now on to the last one IA improvement activities. What should folks be aware of? Any changes there?
Speaker 1:
Yes, and we’re not going to get into it because it starts to get a little complicated. But there are five new improvement activities. They’re removing three of them and modifying one of them. Nothing is earth-shattering. Improvement activity category I always argued it’s kind of a gimme category. There are improvement activities in there that every practice is doing. 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.
Speaker 2:
That’s always a good thing. Check some boxes, get your 15 percent. Move on to the next category, type reporting. There’s always the fourth one. It’s always the most vague, probably the most complaints about, and that is cost. Any concerns or guidance to give some folks on the cost category.
Speaker 1:
I’m not a fan of the cost category. It’s a black box of sorts. You don’t know what your score is in cost until you’ve been scored in cost and there’s no chance for you to change your score. It’s a pain. Now there are ways to go and try to get your cost score ahead of time, but it requires a lot of extra expense. 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.
Speaker 2:
Oh, there you go. Okay, that’s good to hear. That’s good to hear. Well, there’s a 30-year score just about on something that pretty much no one is a fan of on the cost side. All right, so we’ve checked the box there. It’s your traditional MIPS discussion. 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.
Speaker 1:
Yeah, and there’s a lot to cover here, so bear with me. It’s worth talking a little bit about the MVP history. 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.
Speaker 2:
So there’s always questions about if it’s required or not. Is MVP still optional, or are folks required to participate in 24?
Speaker 1:
Yeah, it’s still optional. So by 2028, cms has said that they anticipate MVPs will be the only way to participate in traditional MIPS, that the old smorgasbord, ad hoc way of doing it that goes away and you’ll be forced to pick an MVP. 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.
Speaker 2:
Well, ok, so the windows close as you mentioned, but revisit for folks as they were selecting in 24, in which you maybe anticipate, looking in your crystal ball again, how many different MVPs are folks able to choose from and kind of talk to about? Is it by specialty, primary care? Speak to that a little bit.
Speaker 1:
Right Well, so right now there’s 16. So there’s 16 MVPs right now. The specialties they’re targeting they overlap. For example, coordinating stroke care to promote prevention and cultivate positive outcomes. Now that’s a mouthful that is appropriate for neurology, neurosurgical and vascular surgery specialties. So there’s three specialties that that one MVP covers. 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.
Speaker 2:
You’ve been listening to Beyond the Stealth School about all conversations with SHB. This has been a production of strategic health care partners.
Speaker 1:
Your hosts are Jason Crosby and me Aaron C Higgins.
Speaker 2:
This episode was produced and edited by Nile and Weaver.
Speaker 1:
Our social media content producer is Jeremy Miller.
Speaker 2:
The transcribers Heather McLean, and our executive producers are Mike Scribner and John Currie.
Speaker 1:
For more information about SHP, the services we offer, including the back library of episodes, episode transcripts, links to resources that we discussed, and much more, please visit our website at shpllccom. Slash podcast. Thank you for listening.