What to expect for MIPS 2024
Answers in Practice
By Olivia Barry, Manager, Practice Management, April 1, 2024
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff explains what to expect for MIPS 2024.
On Nov. 2, 2023, CMS released the final Quality Payment Program (QPP) Rule which includes annual requirements for the 2024 MIPS performance year. The extensive thousand-page rule is brimming with intricate details and technical language. To assist you in ensuring your compliance and maximizing your chances of success, explore the AAD’s overview of this year’s MIPS requirements.
It is the seventh year of the MIPS program and it’s evident the requirements have grown more complex. To avoid a 9% penalty and increase your chance of earning an incentive, your practice should adopt and/or utilize an electronic health record (EHR) system, unless exempt.
With 2023 reporting complete, it is time now to delve into the 2024 reporting requirements.
Payment adjustment
The penalty for not participating in 2024 will remain 9% as legislated by law. See the full program timeline below.
Eligibility criteria
You are required to participate if all the following are true (same as 2023):
Bill more than $90,000 for Part B covered professional services, and
See more than 200 Part B patients, and
Provide 200 or more covered professional services to Part B patients
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 you check if you are required to participate on the QPP website.
MIPS 2024
Access our 2024 MIPS reporting options with guidance tailored to your practice size and needs.
Performance thresholds
The threshold to avoid the penalty has remained the same as in 2023. The minimum score to avoid the penalty is 75 points.
The additional performance threshold for exceptional performance was eliminated in 2023, and this continues in 2024. The 2022 performance year was the last year clinicians could earn an exceptional performance bonus.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or as virtual groups. Note: For the 2024 performance period, the virtual group election deadline was Dec. 31, 2023.
Performance categories
All category weights have remained the same from 2023. See details below or visit the AAD Practice Management Center for more information on 2024 MIPS categories.
Quality 30%
(NEW) Data completeness threshold is 75%
Improvement Activities 15%
Performance period: 90-day continuous performance period between Jan. 1 – Dec. 31, 2024. The last day to start a 90-day performance period is Oct. 3, 2024.
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%
(NEW) Performance period: 180-day continuous performance period between Jan. 1 – Dec. 31, 2024, up from 90 days in previous years. The last day to start a 180-day performance period is July 5, 2024.
CMS revised the definition of CEHRT to align with the Office of National Coordinator for Health IT (ONC)’s regulations. You can check your EHR system on the Certified Health IT Product List to ensure it has been successfully tested and certified by the ONC Health IT Certification program.
Updated measures (PI scoring remains the same from 2023)
Eligible clinicians are highly encouraged to adopt an electronic health record (EHR). 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 AAD’s CMS-certified registry DataDerm™. Check 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.
Academy EHR resources
Need guidance on adopting an EHR? Explore Academy resources.
Small-practice accommodations
All small-practice (15 or less clinicians) accommodations remain the same in 2024:
Claims-based reporting allowed for the Quality category
3 points awarded per quality measure that do not meet the 75% 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 the CMS 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%.
Extreme and uncontrollable circumstances
MIPS-eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances that impact these performance categories. To apply, visit the CMS website.
MIPS Value Pathways (MVPs)
The option of participating in an MVP began in 2023; but is not required.
CMS plans to require MVP participation beginning in 2026.
Eligible clinicians may participate in MVPs via subgroups 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 16 MVPs available for voluntary reporting in 2024, including five revised MVPs from 2023.
There are no MVPs available in 2024 that are specific to dermatology.
For more information on MVPs visit the CMS website.
Simplify MIPS reporting with the Academy’s resources, such as a step-by-step guide and interactive tools. The most effective way to optimize MIPS participation is by integrating your EHR with DataDerm or adopting an EHR if you haven’t already. Without an EHR and without qualifying as a special status group for an automatic exemption, meeting the minimum score to avoid penalty will be a challenge. Explore the Academy’s EHR resources to identify the right EHR for your practice and reduce administrative burden while streamlining practice workflow.
Find more information, visit the Practice Management Center.
Guidance and information:
