MIPS archive

Eligibility criteria

The low volume threshold remains the same as 2022 and includes 3 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.

The opt-in policy also remains the same. It allows physicians or groups who meet one or two of the low-volume threshold criteria to opt-in to participate in MIPS and receive a final score and payment adjustment.

Payment adjustment

The 2023 performance period payment adjustment remains at 9% applied to reimbursements in 2025.

Minimum threshold

Minimum points needed to avoid penalty: 75 points (no change since 2022).

Maximum threshold

The Final Rule established there will no longer be an additional performance threshold for exceptional performance in 2023. The 2022 performance year is the last year clinicians can earn an exceptional performance bonus. 

MIPS category breakdowns

Quality: 30% of MIPS score

• No change in category weight from 2022.

• Total of 198 quality measures available for the 2023 performance period.

• Data completeness remains at 70% (but will go up to 75% in 2024)

  • Small practices (15 providers or fewer) receive 3 points for not meeting data completeness.

  • Large practices (16 providers or more) receive 0 points for not meeting data completeness.

• Performance period: Jan. 1 – Dec. 31, 2023.

• Submission methods: claims (for small practices), registry, QCDRs such as the Academy's DataDerm^TM with EHR integration, and your practice’s EHR.

• 6 bonus points added to quality category for small practices (15 providers or fewer) as no changes noted in QPP comparison table.

• Expanded the definition of a high priority measure to also include health equity-related quality measures.

• Facility-based MIPS eligible clinicians now eligible to receive the complex patient bonus.

Improvement Activities: 15% of MIPS score

• No change in category weight from 2022.

• Medium- and high-weighted activities available.

• Performance period: 90-day continuous performance period between Jan. 1 – Dec. 31, 2023.

• Participating clinicians do not have to perform activity at the same time.

• Added four new activities, modified five current activities, and removed five existing improvement activities from the IA inventory.

• Group participation threshold remains the same as 2021 (50% of participation of eligible clinicians in group).

• Submission methods: CMS or QCDR.

Promoting Interoperability: 25% of MIPS score

• No change in category weight from 2021.

• 2015 CEHRT required (Certified EHR Technology).

• Performance period: continuous 90-days between Jan. 1 – Dec. 31, 2023.

• Submission methods: registry, QCDRs, EHRs.

• Updated scoring to accommodate new/revised measures.

• Updates to measures:

  • The Health Information Exchange objective measures points are set at 30 down 10 points from 2022. Three reporting options available for this objective. Also, added participation in the Trusted Exchange Framework and Common Agreement (TEFCA) to the list of options for satisfy this objective.

  • The Public Health and Clinical Data Exchange objective points increased from 10 to 25 points. Active engagement Options 1 and 2 are combined into a single option titled “Pre-production and Validation” and renaming Option 3 to “Validated Data Production” for a total of 2 options. And, eligible clinicians must submit their level of engagement along with yes/no attestation.

  • The Provide Patients Electronic Access to Their Health Information measure points decreased to 25 from 40 (down 15 points from 2022).

  • The Query of PDMP measure is now under the “Electronic Prescribing” objective and required (no longer a bonus measure) worth 10 points. The measure will include not only Schedule II opioids, but also Schedule III, and IV drugs. And there are 3 specific exceptions available.

• CMS is discontinuing PI automatic reweighing beginning in 2023 for nurse practitioners, physician assistants, certified nurse anesthetists, and clinical nurse specialists.

• CMS will continue to automatically reweight the Promoting Interoperability performance category and more heavily weight the Improvement Activities performance category for small practices. 

  • If both Cost and Promoting Interoperability are reweighted, Quality and Improvement Activities will each be weighted at 50%.

Cost: 30% of MIPS score

• No change from 2022.

• No action required by eligible clinician.

• A maximum cost improvement score of one percentage point out of 100 percentage points is established for the cost category. 

Scoring

The overall scoring methodology for each category remains the same as 2022.

Reporting type: group vs individual reporting available

Individual: Under an NPI number and TIN where they reassign benefits; report via claims, registry, or EHR.

Group: Two or more clinicians (by NPIs) who have reassigned their billing rights to a single TIN; report via claims, registry, or EHR.

• Small practices, excluding those participating in MIPS as part of a virtual group, must submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.

Small practice accommodations

Accommodations for small practices include:

• 3 points for measures that do not meet data completeness of 70%.

• Claims-based reporting available.

• 6 bonus points added to numerator of quality category as no changes were noted in the QPP 2022/2023 comparison table.

• Automatic redistribution of the Promoting Interoperability performance category weight for any small practice that does not submit data for the performance category.

MIPS Value Pathways (MVPs)

• The option of participating in an MVP will begin in 2023.

• There are 12 MVPs available for voluntary reporting in 2023 including 5 new ones: cancer care, kidney health, episodic neurological conditions, neurodegenerative conditions, and promoting wellness.

• 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.

Telehealth

• CMS will include the telehealth indicator on clinician profile pages.

• CMS is extending the application of certain Medicare telehealth flexibilities for an additional 151 days after the end of the PHE for COVID-19, including allowing Medicare telehealth services to be furnished to patients located anywhere within the U.S.

• CMS is extending services that are temporarily included on the telehealth services list for an additional 151 days after the PHE.

Additional information

For more information visit the CMS Fact Sheet on the 2023 Medicare Physician Fee Schedule.

You can also access the complete 3,304 page text of the 2023 MPFS Final Rule.