Notice of Proposed Rule Making: Quality Payment Program (QPP):  | Burrows Consulting

Notice of Proposed Rule Making: Quality Payment Program (QPP): 

Quality Payment Program (QPP) Fact Sheet and Policy Comparison Table

The proposed policies keep the focus on the future of MIPS by continuing the development and maintenance of Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs). 

  • Propose to establish the Alternative Payment Model (APM) Performance Pathway (APP) Plus quality measure set (for more robust quality measurement)
  • Proposing updates to the MIPS measure/activity inventories and scoring methodologies to provide all clinicians the opportunity to successfully participate in MIPS.
  • Proposing a small number of policies intended to maintain stability within the MIPS program through the established performance threshold and data completeness criteria.
  • The Request for Information (RFI’s) related to increasing adoption of 
    • MVP reporting and subgroup participation, 
    • The Public Health and Clinician Data Exchange Objective within the Promoting Interoperability performance category
    • Guiding principles for the development of patient-reported outcome quality measures
    • Changes to the administration of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey

Public Health and Clinical Data Exchange Objective this RFI focuses on how CMS can leverage the Public Health and Clinical Data Exchange Objective requirements under the Promoting Interoperability performance category to improve:

  • timely reporting
  • the quality and completeness of reported data
  • overall participation in critical public health reporting 

Among other items, this RFI is soliciting feedback on: 

  • Information on current reporting burden and challenges, such as variance in public health readiness and capacity/capabilities.
  • Opportunities to further advance core objectives around timely, complete, quality data exchange. 
  • The best way to balance the vast array of public health reporting needs and the burden and loss of focus associated with too many measures. 
  • Opportunities for the Medicare Promoting Interoperability performance category to better incentivize the adoption of more advanced information exchange standards and mechanisms.

See fact sheet for more!

Quality Payment Program

Important dates and deadlines for Merit-Based Incentive Payment System (MIPS) 

July 5, 2024 (NEW)

  • Last day to begin data collection for a continuous 180-day performance period for the Promoting Interoperability performance category in the 2024 performance period (reporting period increases beginning in 2024 to 180 days).

October 2024

October 2024

  • The 2025 virtual group election period opens, allowing solo practitioners and groups with 10 or fewer clinicians to submit an election to participate in MIPS as a virtual group for the 2025 performance period.
    • Note: 2025 virtual group election period details will be available on the QPP website later this year.

October 3, 2024

  • Last day to begin implementing an activity for a continuous 90-day performance period for the improvement activities performance category in the 2024 performance period.
    • Note: Most, but not all, improvement activities have a continuous 90-day performance period, but several improvement activities require completion of modules where there’s a year-long or alternate performance period. The performance period is 90 days unless otherwise stated in the activity description. 

October 2024

  • The final day to request a MIPS targeted review for your 2023 MIPS final score will be 60 days after the release of 2025 MIPS payment adjustment factor(s).
  • The exact date will be identified when we announce final performance feedback is available.
  • You’d only request a targeted review if you believe there’s an error in your MIPS performance feedback. 

November 2024

December 2, 2024

  • Last day to register to report a MIPS Value Pathway (MVP) for the 2024 performance year.
  • Learn more about MVP registration.

December 2024

December 31, 2024 

January 2, 2025

  • Data submission period opens for the 2024 performance year.
 

2024 Incentive Payments for Advanced Alternative Payment Model now available!

The Centers for Medicare & Medicaid Services (CMS) has posted the Advanced Alternative Payment Model (APM) Incentive Payments for 2024 (ZIP, 3 MB) on the Quality Payment Program (QPP) Resource Library. This resource provides information about the amount of Advanced APM incentive payments that were paid to eligible clinicians this year based on their participation in Qualifying APM Participant (QP) Performance Period 2022. 

You can now log in to the QPP website using your HARP credentials (ZIP, 3 MB)  to see the amount your organization was paid for both the 10-digit National Provider Identifier (NPI) and the organization.

If you have not received your payment, you should check for your name on the 2024 QP Notice for APM Incentive Payment ZIP File (ZIP, 599 KB), which indicates that you will need to verify your Medicare billing information. If you do not verify your Medicare billing information by September 1, 2024, then CMS will not be able to issue your APM Incentive Payment. For instructions on how to verify your Medicare billing information, review the Zip File (ZIP, 599 KB).

You will not need to do anything to receive your payment, unless CMS is unable to verify your Medicare billing information.

Please contact Melissa Jones, CRHCP

Rural Health Clinic Senior Associate, Burrows Consulting at melissa@burrowsconsulting.net with any questions. 

Reference https://www.narhc.org/News/30651/CMS%2DPublishes%2DAnnual%2DProposed%2DRules%2Dwith%2DSignificant%2DRHC%2DProvisions https://www.cms.gov/newsroom/fact-sheets/cy-2025-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-centerhttps://www.federalregister.gov/documents/current#centers-for-medicare-medicaid-services file:///C:/Users/melis/Downloads/2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf https://qpp.cms.gov/

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