Review of the QPP Final Rule for 2024: Part 2

Aaron Higgins: 0:19
Welcome to Beyond the Stethoscope, Vital Conversations with SHP. I’m your co-host, Aaron C Higgins. On today’s episode, Jason Crosby finishes his interview with me. As you may recall, in our last episode we talked about the final rule that was recently released by CMS the 2024 Quality Payment Program, or QPP. Today, we’ll finish up discussing all the changes that the program will see for APMs and ACOs in addition to the traditional MIPS. We’ll also dive a little bit into the exclusion windows that are quickly closing. Are you ready for this Vital Conversation? Let’s get started.

Jason Crosby: 1:06
We’ve got some backdrop, we’ve got some history, we know we’ve got to choose from 16 of them. Now we know what’s, especially depending if I’m a GI doctor or whatever the case may be. Now let’s get into the weeds a little bit, explain a little bit how it works exactly.

Aaron Higgins: 1:20
Yeah, so I’ve kind of hinted at it. At each MVP there will be pre-selected quality measures, improvement activities, cost measures that are applicable, and then what they call the foundational level, and that’s the Promoting Interoperability, and then a new foundational level that they’re calling population health. We’ll cover that here in a second. So let’s go back to the Optimizing Chronic Disease Management MVP as our example, because it’s a little easier to say so inside that, if you look inside that MVP, you’ll find nine quality measures. You get to pick four of those nine. So right now, if you’re doing ad hoc, you have to choose six this fewer to pick from. Or if you’re a small practice, so you have 15 or fewer clinicians, you only need to pick three. So that’s great. Then you pick one high-weighted or two medium-weighted improvement activities from their approved list. Again, it’s kind of a curated list of things that they think at practice in this specialty or this MVP would be doing. Then, of course, the promoting interoperability assuming you don’t exempt yourself from it and then you have to pick one population health measure. Which population health measures are a new thing in terms of definition, but they’re not new in terms of what they are. They’re quality measures that have the population health category attached to them, because each measure has its own family that it lives in. So these population health measures, these will be done automatically through claims data, so they’re going to be looking at it from a claims level and so you don’t need to submit an extra quality measure. So that’s nice. Again, administrative burden lifted just a little bit.

Jason Crosby: 3:14
That can be overwhelming, I guess, particularly if I’m not as acclimated, perhaps. So break that down a little bit. Why should I not feel overwhelmed? Why does that not sound like a lot?

Aaron Higgins: 3:26
Well, it sounds complex but it actually really is more simple than it is today. Like I said, this is a smorgasbord. We have this huge menu. It’s kind of like going into Cheesecake Factory and you’re just completely overwhelmed when they hand you a menu the size of the phone book. Imagine trying to pick that every year and go through that every year. Well, that’s kind of what you’ve had to do with QPP. You’ve had hundreds of measures, hundreds of recruitment activities, and then hope and pray to God that the right cost measures are associated to you, because you have no control over that, and so all of that worry kind of goes away. You’re instead offered a smaller menu in about nine or so, and it depends on the MVP. Some MVPs have an even smaller list of quality measures. So you have this nice little small list to pick from and you can be hyper-focused on those things. So it should be less overwhelming.

Jason Crosby: 4:23
I like that. Little comfort there, little comfort. All right, I want to go back, because you mentioned a buzzword we hear way too much, but it’s new to us. In terms of the MVP, you mentioned the new population health measure. Tell us a little bit about that.

Aaron Higgins: 4:38
Yeah. So to expand upon that, there’s a handful of population health measures that exist today. So if you wanted to and you can you can go out to the QPP portal. You can pull up the list of all the quality measures and you can look in the category and you can look for population health. It’ll be those measures they will be pulling from for the MVPs and, again, these are going to be based off of claims data, because they’re looking at more than just your care that you provide. They want to look at the care of the patient as a whole. So it’s almost more like a cost measure than it is a quality measure, and that’s why they’re giving it a new name population health measure. So you get a pick. So, unlike the cost, where you don’t get to pick which ones, you do get to pick which one that they should look at for you. But you yourself, you don’t need to do anything and it’ll all come from the claims data.

Jason Crosby: 5:34
Oh, OK. Ok, that makes it a little bit more easy to digest. All right, Now let’s switch gears a little bit. If someone does want to participate in MVP, either as a volunteer group practice or a clinician, how do they go about doing so?

Aaron Higgins: 5:50
Well, the self-nominations. By the time this is heard again, it’s closed. It closes at the end of November and that will be the case for next year as well. So my recommendation if you’re hearing this for the first time and an MVP sounds interesting, you want to participate as an MVP? Fantastic, cms would love to help you. But the nomination window isn’t going to open until the summer. So take a look at the MVPs, see if there’s something that you want to participate in in 2025, and start maybe modeling towards that, maybe for 2024,. Those are the measures that you submit in your traditional MIPS are the same ones that’ll be in your MVP. Use 2024 as that transition year. Again, you have a few years before it’s mandatory, but I would suggest you get on board now. There’s some benefit to that.

Jason Crosby: 6:40
Yeah, good advice, good advice. Okay, let’s switch to another three letter acronym here. What about those of our listeners who are in an APM and alternative payment model like an ACO? Has CMS changed anything with those entities?

Aaron Higgins: 6:54
Yes. So I suspect most of the listeners who are in an ACO or some kind of APM there’s not a whole lot changing, but it’s enough to cover but also those who are in traditional MIPS should continue to listen to, don’t just turn us off or skip to the next podcast. We got a lot to cover. So a particular interest certified EHR technology, or what we call CEHRT. That has changed. It was confusing. You have to have a 2015 CEHRT. Well, I mean, it’s 2023, 2015. That was just a year that the certification was made and didn’t necessarily exactly reference the fact that the last time the EHR was updated it got to be very confusing. So CMS has said no more of that. Instead, if you want to participate in an APM, an ACO or traditional MIPS, you instead have to have a minimum version certification, which will be maintained by the Office of the National Coordinator for Health IT, called ONC. Onc has always done the certification, so that’s not changing. But going forward, they will now be the lone decider of what is a valid version of the EHR for QPP participation. So what that means? They’re doing away with their own versioning system anyway, because they’re dropping the year from the certification number, which, again. It makes sense, because it was really confusing. Instead they’re going to a new numbering system and there’s a whole release all about that. We won’t get into that here Now. Cms will just point to ONC and say whatever version they’re saying is the version you need to have, is the version you need to have for QPP. So that applies to everybody who participates in any form of quality. They need to have whatever the latest required certified version is. I would recommend that you pay close attention and stay up to date on your updates. Furthermore, 75 percent of the participants in an ACO or an APM must be using CE HRT. The reason for that is you had a lot of APMs or ACOs that had providers not on EHRs at all. They were on paper charts or they were on some really clucky home-built system that wasn’t certified. It became a haven for those who were resisting converting to digital charts. CMS has sent no more. 75 percent was the whole number and now in order to participate in an APM, it must be 100 percent. That could be big. If you’re practice hiding out in an ACO still using paper charts, you will no longer be allowed to participate in the ACO, so bear that in mind.

Jason Crosby: 9:55
That’s a major decision point, that’s for sure. Wow, yet another thing to keep track of. I’ve heard you say this over and over and I’m sure those who are listening have listened to you before have heard you comment. Is this just another thing that practices the admins and the docs have to keep track of with regards to the EHR version, or what?

Aaron Higgins: 10:17
Well, yeah, certainly talk to your EHR vendor, make sure you have the latest and greatest of the CEH RT Before you submit and particularly before you enter certain reporting periods, particularly around promoting interoperability. So by June you need to make sure that you are using whatever the latest CEH RT certified version. EHR what have you is running, because that’s that promoting interoperability is tied to your CEHRT version.

Jason Crosby: 10:51
Probably a good idea, as you’re listening to this, getting in touch with someone in your office, or getting touch with your vendor as a suggestion. See where you’re at, get a game plan together. So it’s not last second. Any other ACO or APM updates that you want to tell our audience about?

Aaron Higgins: 11:08
Yeah, this one doesn’t apply to traditional MIPS because you already have to do promoting interoperability Now, going forward in 2025, so you have one year to get used to it. Anybody participating in an APM must also report promoting interoperability. Some ACOs, some APMs have been exempt from that, for whatever reason. That goes away. So just reach out to your APM coordinator or your ACO coordinator and ask them are you reporting promoting interoperability or do we have to do that? That way, you can be prepared by 2025.

Jason Crosby: 11:40
Let’s revisit. In past year, CMS has offered an incentive payment on the APM side, typically about 5 percent of the clinicians estimated payments for what I understand. How’s that change at all? Okay?

Aaron Higgins: 11:54
Yes, it has changed, but I needed to find something first. It’s that alphabet soup. So when a clinician participates in an APM, they receive a designation called Qualified Alternative Payment Model Participant or, as we abbreviate it, qp. That makes it easy. So this process is not going to change. It was in the proposed rule. It was taken out, so they were going to actually make it harder to become a QP. They’re changing it so those who are QPs now will stay QPs and those who meet the requirements can still follow the process that exists today. So clear as mud, I’m sure Now the incentive payment made to QPs is going to change. So right now, reporting year 2023 means payment year 2025, because we report our data in 2024. It’s evaluated and released in June, so you don’t actually start receiving that 5% incentive until the following January 1, 2025. Got it? So they’re doing away with that. So 2023 is the last year that 5%. You’re still going to see it in 2024 if you qualified for it last year or if you’re doing it this year, 2025. So any new QPs starting January 1, 2024 will not see the incentive. Instead, into performance year 2024 and beyond, existing QPs will still receive a higher Medicare or part of me fee schedule. So the PFS called the qualifying APM conversion factor of 0.75% compared to non QPs. Non QPs will receive at 0.25 Medicare PFS update which will result in a differently higher PFS payment rate for eligible clinicians who are also QPs. So you can be an eligible clinician, participate in an APM and still also receive some of the MIPS incentive payments is what it’s saying here. So you can not double dip, but you can be double incentivized. Eligible clinicians who are QP for a year will continue to be excluded from certain MIPS reporting and payment adjustments for the year. So this again clears mud. This is the change that’s coming. If you don’t know what the heck I’m talking about, it probably doesn’t apply to you.

Jason Crosby: 14:25
Well, it’s too bad to see any incentive go away. You know that’s something that’s been influential for some folks, so it’s too bad to see that going away.

Aaron Higgins: 14:37
Yeah, I hate seeing it, but it’s been around since 2019 and we know Washington they take away all the toys.

Jason Crosby: 14:45
Yeah, I try. All right, I know we’ve thrown a lot out there, but what else? Any other updates or takeaways that folks need to know about as as they listen to this going on the 24 year?

Aaron Higgins: 14:57
Yeah, so we didn’t talk about exemptions or exclusions from the various categories, but you are quickly running out of time to file for those, if that is something that you qualify for. So if you’ve had a qualifying extreme or incontrollable circumstance, you have until January 2nd that’s Tuesday, January 2nd 2024 to exclude yourself from MIPS 2023. There’s a whole list on the website. It’s qpp. cms. gov and you can go and you can click on the exclusions tab. There’s a link on the bottom of the page and you can see if you qualify. So things like tornadoes, hurricanes, floods, fires, natural disasters, those sort of things can qualify. Other things don’t. So if you, let’s say, you have a ransomware attack, that may not qualify, so be aware of that. So if you miss a significant chunk of 2023 and you can’t hit your 75 points, look at that. That doesn’t mean it means you’re not going to get a payment, so your incentive is zero, but it’s better than getting docked for it. Now. The same goes for the promoting interoperability performance category hardship exemption. There are certain criteria you must meet and so if, for whatever reason, you meet that, you want to get a zero on your promoting interoperability but you did fine on everything else, you can claim that and I’ll put a link in the show notes specifically to that so you can go there and find out. Now, that being said, small practices, which traditionally are 15 or fewer clinicians, according to CMS definitions, has traditionally, for the last few years, been exempted from promoting interoperability. So you could go and you could apply and you can say hey, I’m a small practice. Promoting interoperability is too difficult for me to achieve. Cms started doing that a couple of years ago. They haven’t said it’s going away, but they also haven’t released the exemption form for that yet. So be on the lookout for news if you’re planning on that. Cms hasn’t said anything, so I want it. Bet on it it may be going away, so just just bear that in mind.

Jason Crosby: 17:09
Wow, that’s a lot to keep track of. I know we probably have overwhelmed some folks, but that’s again why we record this right. So, anyhow, great information, great conversation, aaron. We’ve done this for a couple of years in a row. I’m sure folks find it helpful. Really good information, as folks. As Aaron suggested, feel free to look in the show notes for references. I want to thank you all for listening, and also to our guest and my esteemed partner, crime Aaron, who took a lot of time out to prepare for this and to present, and I wish you all a wonderful day. Thanks, aaron.

Aaron Higgins: 17:47
Yeah, you’re welcome. You have a good one.

Jason Crosby: 17:55
You’ve been listening to Beyond the Stethec ope, Vital Conversations with SHP. This has been a production of strategic health care partners.

Aaron Higgins: 18:03
Your hosts are Jason Crosby and me, Aaron C Higgins. This episode was produced and edited by Nyla Wiebe and social media content producers Jeremy Miller, the transcriber is Jason Crosby and our executive producers are Mike Scribner and John Crew. 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 shpllc. com. Thank you for listening.