2024 MIPS update

By Allison Evans, Assistant Managing Editor, May 1, 2024

“If you provide Medicare services, MIPS is a must when it comes to your reimbursement,” said Florida dermatologist Shawna Flanagan, MD, FAAD, member of the Academy’s Practice Management Committee. “With fee schedules decreasing, you want to optimize all your opportunities for higher reimbursement and avoid penalties at any cost.”

On Nov. 2, 2023, CMS released the 2024 Medicare Physician Fee Schedule Final Rule, which included annual requirements for the 2024 MIPS performance year. As a result of the AADA’s advocacy, the final rule included several significant wins, said Olivia Barry, MPH, the Academy’s manager of practice management. “First, the MIPS performance threshold for 2024 will be maintained at 75 points, rather than the proposed 82 points. This is a crucial win because 50% of physicians were projected to face penalties under the higher threshold. Maintaining the performance threshold at 75 points reduces the number of physicians predicted to incur penalties to 22%,” she added.

MIPS eligibility criteria

The low volume threshold remains the same as in 2023 and includes three aspects of covered professional services:

1. Allowed charges

2. Number of Medicare patients who receive services

3. Number of services provided

You must participate in MIPS (unless otherwise exempt) if, in both 12-month segments of the MIPS Determination Period, you:

• 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.

Learn more about the MIPS Determination Period on the CMS website.

The voluntary opt-in policy also remains the same, allowing some physicians, 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 in MIPS on the CMS website.

Payment adjustment

The 2024 performance period payment adjustment remains at 9% — applied to reimbursements in 2026. The minimum points needed to avoid the penalty is 75 points (no change since 2023). The additional performance threshold for exceptional performance was eliminated in 2023, and this continues in 2024. The 2022 performance year was the last year physicians could earn an exceptional performance bonus.



Quality

Just as in 2023, the MIPS quality category will be 30% of the MIPS score. There will be a total of 199 quality measures available for the 2024 performance period. (View all the measures on the CMS website. View the 27 quality measures available to report via the Academy’s DataDerm™ clinical data registry.)

“This year, there are two new MIPS quality measures available to report via DataDerm. There are in total 11 new MIPS measures in the program, and one new QCDR measure, which can only be reported with DataDerm,” said Stephanie Braxton, the Academy’s senior manager of performance measurement and analysis. The new MIPS measures are 498: Connection to Community Service Provider, and 503: Gains in Patient Activation Measure (PAM) Scores at 12 Months. The new QCDR measure is AAD19: Psoriasis – Shared Decision Making in the Treatment of Psoriasis.

Against the AADA’s urging, CMS finalized removing the topped-out MIPS measure 138: Melanoma Coordination of Care. Other measures that have been removed include MIPS measure 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, and AAD 11: Skin Cancer Surgery: Post Operative Complications. Additionally, CMS finalized removing MIPS measure 402: Tobacco Use and Help with Quitting Among Adolescents because it believes the measure is duplicative to measure Q226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention. Q226 was expanded to include patients between 12-17 years of age, added Braxton. View all 2024 quality measures for MIPS.

Braxton recommends other dermatology-specific measures that could be used in place of the removed measures, including:

• MIPS 137: Melanoma: Continuity of Care - Recall System

• MIPS 440: Skin Cancer: Biopsy Reporting Time - Pathologist to Clinician

• MIPS 485: Psoriasis: Improvement in Patient-Reported Itch Severity

• MIPS 486: Dermatitis: Improvement in Patient-Reported Itch Severity

There are also several AAD QCDR measures (reportable only via DataDerm) available for reporting, Braxton added.

“Review your scores on a monthly basis if you are using a registry with a dashboard; this will give you and your staff insight into how you are doing on each measure and areas to focus on for improvement,” said Kevin Crawford, MD, FAAD, deputy chair of the Academy’s Practice Management Committee and a Mohs surgeon in Indiana.

Changes to 2024 quality measures for MIPS reporting:

Improvement activities

For 2024, the improvement activities category will comprise 15% of the total MIPS score. “In 2023, there were 81 dermatology-specific improvement activities (IAs),” said Mona El-Shamaa, manager of Quality Improvement at the Academy, “although there have been a few changes to the dermatology-specific IAs for 2024.”

There will be two new dermatology-specific IAs: IA_PM_22 Improving Practice Capacity for Human Immunodeficiency Virus (HIV) Prevention Services, and IA_MVP Practice-Wide Quality Improvement in MIPS Value Pathways. One dermatology-specific improvement activity has been modified: IA_PSPA_16 Use decision support — ideally platform-agnostic, interoperable clinical decision support (CDS) tools — and standardized treatment protocols to manage workflow on the care team to meet patient needs; and one IA has been removed: IA_ PSPA_29 Consulting Appropriate Use Criteria (AUC) Using Clinical Decision Support when Ordering Advanced Diagnostic Imaging.

Changes to 2024 dermatology-specific improvement activities for MIPS reporting:

Promoting interoperability

As in 2023, the promoting interoperability category weight remains at 25% of the MIPS score. “What is new for 2024 reporting is the performance period is now a continuous 180-days between Jan. 1 – Dec. 31, 2024 — up from 90 days in previous years,” said Barry.

For 2024, CMS has revised the definition of CEHRT to align with the Office of National Coordinator for Health IT (ONC)’s regulations. You can check your EHR on the Certified Health IT Product List (CHPL) to ensure it has been successfully tested and certified by the ONC Health IT Certification program.

Cost

There are no changes to the cost category from 2023. Unlike the other MIPs categories, dermatologists and other eligible clinicians do not have to actively report data for the cost category. Instead, CMS automatically calculates the physician’s performance score using information from claims data.

If dermatologists perform 10 or more melanoma resections that meet the eligibility criteria for this measure, CMS will automatically apply these to the cost category and assign a score up to 30% of the overall MIPS score. If an eligible clinician does not perform 10 or more melanoma resections in the performance year, they will automatically be exempt from the cost measure, and the weight of this category will be redistributed to other categories.

MIPS exemptions

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), unless exempt, Barry advised.

Just as in 2023, both the Extreme and Uncontrollable Circumstance (EUC) exception and the Promoting Interoperability exception will be available for the 2024 performance year. “CMS anticipates the applications for the 2024 performance year to be available in the spring. Members can visit the QPP hardship exception page for more information,” said Barry.

“Additionally, all small practices will have the PI hardship exemption automatically applied so the PI category will be reweighed to 0. This is the same as 2023,” she added.

Words of wisdom

“Since MIPS is such an important part of reimbursement, most EHRs have a dedicated MIPS specialist who helps guide your practice through the process,” Dr. Flanagan remarked. “Get connected with the appropriate contact with your EHR and set up regular meetings. My office meets quarterly with our MIPS representative.”

The AAD website has some great information on MIPS for clinicians, added Dr. Crawford. “This includes both detailed and abbreviated overviews of MIPS, the categories we are responsible for, the quality measures available and their specifications, reporting details, and other tools to help you determine what path you or your practice should take with MIPS.”

MIPS seems to always be changing, so to be successful with MIPS, you really need to have a designated point person in your practice to stay on top of the reporting measures, recommended Dr. Flanagan. “Here at Genesis Dermatology both my office manager and head medical assistant meet quarterly with our EHR MIPS specialist and report back to update the staff.”

Dr. Crawford agrees. “Help empower the clinical leadership and staff in your practice to understand the importance of MIPS and how they should document the measures you are responsible for reporting. MIPS is a team effort and particularly with the use of scribes in our specialty, staff should have quick guides and reference materials on hand to ensure they know the MIPS workflows for every patient visit.”

Make sure all staff members are aware of what MIPS is and its importance to the practice for reimbursement, Dr. Flanagan emphasized. “At the very least, they need to understand the importance of recording the patient information. Most EHRs now have the reporting process built in, but if the MIPS information being reported is not reviewed with the patient, this could lead to a decrease in patients being recorded for the qualifying measure, therefore, affecting your overall numbers.”

“Develop workflows for staff members that are sustainable to do consistently throughout the year,” Dr. Crawford said. “Choose attainable measures based on your typical patient mix and build documentation for MIPS measures into your normal patient visit workflows for maximum efficiency. Keep MIPS at the forefront of communication and ensure staff are supported as they strive to meet measure requirements.”

MIPS Value Pathways

In 2020, CMS created a new participation pathway under the Quality Payment Program (QPP) called MIPS Value Pathways (MVPs). MVPs are CMS’s response to physicians and practices struggling within the current MIPS program. It is the newest MIPS reporting option — an alternative to traditional MIPS and APMs — that you can use to meet your MIPS reporting requirements. Each MVP includes a subset of measures and activities that are related to a given specialty or medical condition, which includes a small number of quality measures, improvement activities, and cost measure(s).

In 2023, CMS gave notice that it had drafted a dermatology-specific MVP for the 2025 reporting year. On Jan. 29, 2024, the AADA strongly urged CMS not to proceed with its MVP for Dermatological Care.

The Academy argued that CMS’s current approach to its candidate MVP overlooks the diverse subspecialties within dermatology. The AADA emphasized that each subspecialty within dermatology provides unique services to distinct patient populations with varying practice patterns. This diversity in the practice of dermatology makes a one-size-fits-all model ineffective for comparing the cost and quality of care. For example, dermatologists who treat psoriasis (which is currently considered in quality measures) may not treat melanoma (which is currently the only measure related to cost). If CMS decides to combine a cost measure for a cancer-related disease with quality measures for a skin condition like psoriasis, it separates the important connection between the cost and quality of care, making it difficult to determine the value of patient care.

CMS intends to phase out traditional MIPS and mandate MVP reporting — unless participating in an alternative payment model (APM). Until this happens, however, members may choose to submit via both pathways — traditional MIPS and an MVP. CMS will automatically select the better score. The AADA plans to meet with CMS to reiterate its concerns with the candidate MVP for Dermatological Care and urge the agency not to proceed as currently drafted.

Additional DermWorld Resources