The 2024 holiday season is here and the stakes for MIPS participants have never been higher. Now is the time to make your list, check it twice, and ensure your organization stays off the penalty "naughty list."
This season, the gift of preparation could save you from costly penalties and even earn future incentives. Don’t leave it to chance. Let’s unwrap what you need, to finish strong.
Key Changes for 2024
Exceptional Performance Bonus no Longer Available
For years, high-performing providers benefited from the exceptional performance bonus. This additional incentive helped offset the challenges of achieving high scores. However, as of 2023, this bonus is no longer available. Providers will need to rely solely on their MIPS scores and points earned from the four performance categories - Quality, Promoting Interoperability, Improvement Activities, and Cost.
No More EUC Exceptions for COVID-19
The COVID-19 pandemic provided some opportunity to opt out of MIPS with the Extreme and Uncontrollable Circumstances (EUC) exception. However, this option has been removed for the 2024 performance year. Providers must now fully report, without the potential lifeline of an exception due to pandemic-related challenges.
Unfavorable Quality Measure Benchmarks
The benchmarks for quality measures are the least favorable they’ve been since the program began. Many providers will find it harder to score high in the Quality category, placing even more importance on every other category in MIPS. Providers must review the quality measures for reporting at the beginning of each MIPS year. More measures fall into the topped-out category - meaning a performance rate of 100% will earn only 7 points instead of 10 points. Additionally, a performance rate from the previous year could result in a lower score due to the higher benchmarks. For example, a 50% performance could have received a score of 7 in 2023, but would only earn a 4 in 2024. CMS uses benchmarks to direct providers to report on measures they need more data on. A high benchmark or a topped-out measure is an indicator that CMS has received enough data for that measure and wants to direct you to the measures with more attractive benchmarks.
Increased Data Completeness Requirements
The data completeness threshold has increased to 75% (from 70% in 2023) for 2024 and beyond. This means providers must report at least 75% of eligible cases for each quality measure to earn points in the Quality category. Failure to meet this requirement will lead to lower scores and could make it harder to score the minimum of 75 points needed to avoid penalties.
Understanding Your MIPS Score is Critical
With all the significant aforementioned changes, eligible providers must understand where they currently stand from the MIPS score perspective. Providers need to reach a score of at least 75 points to avoid a 9% penalty on their 2026 Medicare Part B reimbursements. This is a significant risk for those who are falling behind in their MIPS reporting or struggling with stricter benchmarks.
Four Steps to Take Now
1. Review Your Current MIPS Score
If you’re unsure of your standing, now is the time to review your data. Make sure your Quality, Promoting Interoperability, Improvement Activities, and Cost categories are all on track.
2. Maximize Performance in Each Category
With benchmarks tighter than ever, you’ll need to optimize every possible measure. Identify where you can improve and make adjustments before it’s too late.
3. Stay Updated on Reporting Requirements
Ensure that you’re meeting all the updated MIPS requirements, including Security Risk Analysis, SAFER guides, and Provider-to-Patient Exchange under Promoting Interoperability.
4. File Hardship Exception
If your practice encountered any hardship due to natural causes, you would receive an automatic exception regardless of the group size. However, if the Change Healthcare cyberattack significantly impacted your organization’s ability to successfully report the data under all four performance categories, you must file for a hardship exception by Dec 31, 2024, to avail of the exception.
NOTE: If your organization submits any data for any performance category after claiming a hardship exception, it will override the exception.
How Darena Solutions Can Help
At Darena Solutions, we’ve been your trusty helpers, guiding EHRs and provider organizations of all sizes through the challenges of MIPS since the very beginning. As a CMS Qualified Registry, we specialize in turning potential penalties into well-earned rewards.
If you’re worried about ending up on the MIPS naughty list or want to ensure your practice shines brightly on the nice list for 2024 and beyond, we’re here to help.
You wouldn’t want CMS to deliver a lump of coal into your MIPS stocking.
Send your wish list for a personalized MIPS strategy for a higher MIPS score and incentives this season!