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- MIPS Scoring Performance Threshold Remains at 75, Increases Achievement Complexity
As first reported on July 7, the CMS released its proposed 2023 Quality Payment Program (QPP) regulation which outlined more challenging performance thresholds for pathologists. The CMS also provided consistency in MIPS while they gain familiarity with MIPS Value Pathways (MVPs) and move toward accountable care and advanced alternative payment models. Though limited, the proposed changes to the MIPS program could significantly impact pathologists’ scores and payment bonuses.
In the proposed 2023 QPP regulation, the CMS will leave the performance threshold at 75 points. However, the CMS did increase the complexity to reach the scoring threshold, as measures that used to be worth between 3 and 7 points could be worth as little as 1 point. Because the pathology QPP measures are topped out, pathologists must achieve a near-perfect score to get 7 points. Otherwise, if a practice does not achieve a near-perfect score, the practice could receive only 1 point for that measure. Additionally, the exceptional performance bonus pool is no longer available.
In 2023, pathologists reporting MIPS will have to take action to avoid penalties that reduce future Medicare Part B payments for their services. For example, failing to reach the scoring threshold in 2023 could result in Medicare payment penalties up to 9% for payments in 2025.
With the proposed 2023 changes to scoring, it is likely that many small practices – especially those that rely heavily on the topped-out QPP measures – could see a reduction in their MIPS performance scores, leading to penalties. Billing companies alone are not able to avoid this problem for many practices.
The CAP will advocate for pathologists’ success in the MIPS program.