Preparing for MIPS 2023 and beyond
Answers in Practice
By Olivia Barry, Manager, Practice Management, April 1, 2023
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff offer tips on MIPS reporting.
It’s year five of the Merit-based Incentive Payment System (MIPS), so you are probably well aware that program requirements change annually. Those changes can seem complicated and daunting, so here is a breakdown of what to expect and how to be successful for 2023.
On Nov. 1, 2022, CMS released the final Quality Payment Program (QPP) Rule outlining the new requirements for the 2023 MIPS and some of their proposed ideas for future performance years. One of the key takeaways of the requirements is that in order to maximize your chances of success and to avoid getting hit with the 9% penalty, eligible clinicians will need to utilize an electronic health record (EHR) system — unless you get an exemption. Therefore, if you have not already adopted an EHR, this is your sign to do so today, and we have many resources to help!
Now let’s dive into the requirements you should prepare to meet in 2023.
Payment adjustment
The penalty for not participating for 2023 will remain 9% as legislated by law. See the full program timeline below.
Eligibility criteria
The low-volume exemptions for participation in MIPS remain the same as 2022:
Bill ≤ $90K in Part B allowed charges for covered professional services, OR
Provide care to ≤ 200 Part B enrolled beneficiaries, OR
Provide ≤ 200 covered professional services under the Medicare Physician Fee Schedule
The voluntary opt-in option remains, allowing some clinicians, who otherwise would have been excluded under the low-volume threshold, the option to participate in MIPS. Eligible clinicians or groups will be able to opt-in if they meet or exceed at least one or two, but not all three, of the low-volume threshold criterion noted above.
Make sure to check if you are required to participate on the QPP website.
MIPS reporting 101
Learn more about MIPS reporting and the fee schedule.
Performance thresholds
The threshold to avoid the penalty has remained the same as in 2022. The minimum score to avoid the penalty is 75 points. The 2022 performance year was the last year clinicians could earn an exceptional performance bonus. For 2023, there will no longer be an additional performance threshold for exceptional performance.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or as virtual groups. Note: As in years past, for the 2023 performance period, the virtual group election should have been made by Dec. 31, 2022.
Performance categories
All category weights have remained the same from 2022. Also, performance periods remain the same as 2022. See details below:
Quality 30%
Data completeness remains at 70% (but will go up to 75% in 2024).
Improvement Activities 15%
Group participation threshold remains at 50% of eligible clinicians and not all clinicians need to complete the activity at the same time.
Promoting Interoperability 25%
Updated scoring to accommodate new/ revised measures.
Eligible clinicians are highly encouraged to adopt an EHR system. If you have not already, find an EHR that fits your needs to optimize your practice workflow.
If you haven’t already done so, be sure to enroll in the Academy’s CMS-certified registry, DataDerm
TMCheck to see if it can integrate with your EHR.
Cost 30%
No action is needed by the individual clinician/group as CMS automatically calculates this.
A maximum cost improvement score of 1 percentage point out of 100 percentage points is available for this category.
Small-practice accommodations
All small-practice (15 or less physicians) accommodations remain the same in 2023:
Claims-based reporting allowed for the Quality category.
3 points awarded per quality measure that do not meet the 70% data completeness requirement.
6 bonus points added to numerator of Quality category.
Automatic redistribution (no application required) of the Promoting Interoperability performance category weight for any small practice that does not submit data for the performance category.
Note: CMS considers small practices as a special status. For more information on reporting accommodations for small practices and other special statuses, visit QPP website.
When Promoting Interoperability is redistributed, Quality will be 40%, Cost 30%, and Improvement activity 30%.
When Promoting Interoperability and cost are both reweighted, quality will be 50% and Improvement activity 50%.
Three-step MIPS guide
Check out this useful Academy resource for MIPS.
Extreme and uncontrollable circumstances
CMS will automatically reweigh the Quality, Improvement Activities, Cost, and Promoting Interoperability performance categories for MIPS-eligible clinicians who are affected by extreme and uncontrollable circumstances affecting entire regions or locales. To apply visit QPP website.
MIPS Value Pathways (MVPs)
The option of participating in an MVP begins in 2023, but is not required.
CMS plans to require MVP participation beginning in 2026.
Eligible clinicians may participate in MVPs via a subgroup which is a subset of a group that contains at least one MIPS-eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician’s NPI.
There are 12 MVPs available for voluntary reporting in 2023 including five new ones: cancer care, kidney health, episodic neuro- logical conditions, neurodegenerative conditions, and promoting wellness.
There are no MVPs available in 2023 that are specific to dermatology.
For more information on MVPs, visit QPP website.
MIPS reporting can seem overwhelming, but it does not have to be with the help of the Academy’s resources, including a step-by-step guide and interactive tools. Again, the best step you can take to simplify your MIPS participation is to integrate your EHR with DataDerm or adopt an EHR if you haven’t already done so. If you do not have an EHR and do not fall into one of the special status groups to get an automatic exemption applied, it will be challenging to meet the minimum score to avoid the penalty. Visit AAD's EHR resources to determine which EHR may be right for your practice and learn how it can help significantly reduce administrative burdens.
EHR help
Get tips on how to select and maintain your EHR system.
Get more useful and practical practice management resources in the AADA Practice Management Center.
