2024 Physician Fee Schedule Proposed Rule Includes Draft Policy Changes for Quality Payment Program

CMS Proposes Policy Changes for Quality Payment Program

The Centers for Medicare & Medicaid Services (CMS) has issued its proposed policies for the Quality Payment Program (QPP) via the Calendar Year (CY) 2024 Medicare Physician Fee Schedule (PFS) Proposed Rule, with proposals applicable to the 2024 performance year.

These include proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs) about the future of MVPs, alignment of QPP and the Shared Savings Program, and recommendations for publicly displaying data on Care Compare.

We’ve proposed policies that continue the development and maintenance of MIPS Value Pathways (MVPs), support the use of digital measurement and health information technology, amend requirements for third party intermediaries, and update the performance threshold.

2024 Policy Highlights

Some of the key QPP policies that have been proposed in the 2024 PFS Proposed Rule:

• Introducing 5 new MVPs for the 2024 performance year, and revisions to the MVPs already finalized, including adding and/or removing measures and improvement activities based on MVP inclusion criteria and information received through the MVP maintenance process.
• Using the mean final scores from 2017-2019 MIPS performance periods/2019-2021 MIPS payment years to set the MIPS performance thresholds, averaging the mean final score from each of the three performance periods (this would increase the performance threshold to 82 points for the 2024 MIPS performance year). 
• Keeping the data completeness threshold to 75% for the 2024 and 2025 performance years with incremental increases for subsequent performance periods.
• Updating MIPS quality measures and the improvement activities inventory.
• Increasing the performance period for the Promoting Interoperability performance category to a minimum of 180 continuous days within the calendar year.
• Establishing the Medicare Clinical Quality Measures (CQMs) for Accountable Care Organizations (ACOs) participating in the Shared Savings Program (Medicare CQMs) as a new collection type for Shared Savings Program ACOs under the APP.
• Requiring all MIPS eligible clinicians, Qualifying APM participants (QPs), and Partial QPs participating in a Shared Savings Program ACO (regardless of track) to report the measures and requirements under the MIPS Promoting Interoperability performance category at the individual, group, virtual group, or APM Entity level.
• Removing the numerical 75% threshold for certified electronic health record (EHR) technology (CEHRT) for Advanced APMs and instead simply having the Advanced APM require the use of CEHRT for QP performance periods starting in 2024.  

CMS encourages you to submit comments on these proposals. The 60-day comment period for the 2024 PFS Proposed Rule is open until 5:00 PM ET on September 11, 2023. 

For More Information

Learn more about the 2024 PFS Notice of Proposed Rulemaking and the QPP proposals by reviewing these resources:

• Fact Sheet – Provides additional details about the proposed policies for QPP and other CMS initiatives.
• 2024 QPP Proposed Rule Resources:
  • 2024 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table – Outlines proposed revisions to QPP and lists the RFIs included in the 2024 PFS Proposed Rule. Also shows the changes to QPP policies proposed in the 2024 PFS Proposed Rule, in comparison to the finalized 2023 policies.
  • 2024 Proposed and Modified MVPs Guide – Highlights the newly proposed MVPs and modifications to previously finalized MVPs, beginning with the 2024 performance year.