2023 QPP Requirements

The Quality Payment Program has undergone some major changes over the last several years and CMS has signaled that they intend to further modify the program in the years to come. It's hard to keep all the requirements straight. In this article we will cover the major themes that came out of the recent final ruling, review the base requirements for all participants and then review the individual requirements according to a clinician's participation status.

Major Theme Changes

There are three major themes to the changes CMS unfolded as a part of the 2023 PFS Proposed Rule.

Theme 1: MSSP ACOs must start reporting using eCQMs or CQMs. CMS did not extend the deadline for transitioning away from CMS Web Interface measures. That means by 2025, everyone is reporting Quality measures as either eCQMs or CQMs

Also see: eCQM vs CQM vs Web Interface: Understanding the Difference

Theme 2: Subgroup reporting by specialty type is on the horizon. CMS introduced a new reporting framework available for the first time this year called MIPS Value Pathways (MVPs). MVPs include measures that are for specific specialty groups (like rheumatologists). CMS finalized five additional MVPs so while there are 12 different MVPs a group could use to report only seven are available in 2023. Sub-group reporting is optional until 2026 when it becomes mandatory (if you choose report this framework). 

Also see: [E-BOOK] MIPS MVPs: A Guide to Reporting

Theme 3: The end of Traditional MIPS is hovering like a specter above us. CMS didn't commit to it, but they continue to say they are considering retiring the Traditional MIPS reporting framework by 2027, which would mean everyone must report under the MVP reporting framework (subgroup reporting by specialty type required) or be involved with an APM Entity (such as an ACO) and report through the APM Performance Pathway (APP) framework.

Let’s dive into the details.

Understanding MIPS Participation Eligibility

We start by reviewing the types of MIPS participants to understand your options better.

CMS puts Eligible Clinicians into one or more categories.

• Not eligible
  • Clear enough.
• MIPS Eligible Clinician Individual
  • As an individual clinician you are required to report to MIPS.
• MIPS Eligible Clinician Group
  • As an eligible clinician you are required to report to MIPS, and you are able to report as part of a group. Groups are made up of clinicians who all bill with the same Tax ID (TIN).

• MIPS Eligible Clinician Virtual Group
  • As an eligible clinician you are required to report to MIPS, and you are able to report as part of a virtual group. Virtual groups must be comprised of 10 or fewer Eligible Clinicians and, as a group, exceed the low-volume threshold.

• Qualifying APM Participant (QP)
  • This clinician is a part of an Advanced APM Entity and therefore does not have to report to MIPS and automatically receives a +5% payment.
    
    

• MIPS APM Participant
  • This clinician is part of an APM Entity, but it is not an Advanced APM, therefore they still must submit data for MIPS.
    
    

One more thing I’ll add here is that those participation statuses apply to the NPI associated with each provider. We will also be referencing APM Entities in the information below. An APM Entity is responsible for reporting to the MIPS program on behalf of their participants. There are Advanced APMs which take on some form of financial risk. These organizations do not have to report to MIPS. There are other APM Entities which are not designated as advanced. ACOs make up a good portion of these types of organizations. 

As an individual clinician you may have relied on your ACO to report on your behalf.

To find out your participation framework you must check your eligibility on the QPP website.

Three QPP Reporting Frameworks

Once you know your participation status, you will understand which framework you can use for submission. There are three QPP frameworks in 2023, the Traditional MIPS Framework, the APM Performance Pathway (APP) Framework and the MIPS Value Pathways (MVP) Framework.

Traditional MIPS Framework

This is the usual MIPS framework made up of four categories and a composite score.

APM Performance Pathway (APP) Framework

The APP Framework is available to MIPS APM Entities and required for ACOs if they are part of MSSP.

MVP Framework

This is a new framework and is made up of five categories with measures specific to the specialty the MVP addresses. For example one MVP is called Advancing Rheumatology Patient Care. As you would expect, all measures in that MVP would be applicable to rheumatologists.

Here is a matrix of which framework you can report to, based on your status.

Each framework has slightly different requirements and different category weights.

MIPS Framework Category Weights

APP Framework Category Weights

MVP Framework Category Weights

Now before we move on to the category requirements, we need to clarify one more definition, collection types.

Defining MIPS Collection Types

Collection types are the way you report the data to CMS. You can think of them like measures. There are six collection types in 2023.

1. eCQMs (Electronic Clinical Quality Measures)
2. MIPS CQMs (previously called Registry measures)
3. QCDR measures (Qualified Clinical Data Registry)
4. Medicare Part B Claims measures
5. CAHPS for MIPS survey
6. CMS Web Interface measures (available for MSSP ACOs only)

As I mentioned before, CMS Web Interface is going away in 2025 so if this is the primary way you submitted your MIPS measures before, you need to figure out a new collection type soon.

Which collection type you can submit depends upon your participation status. For instance, CMS Web Interface measures can only be submitted by MSSP ACO groups in 2023.

Now we are ready to review the requirements for each framework.

2023 Quality Requirements

2023 Promoting Interoperability Requirements

2023 Improvement Activities Requirements

2023 Cost Requirements 

2023 Population Health Requirements