This summer the center for medicare and Medicaid Services (CMS) published its annual Physician Fee Schedule and Proposed Rule for calendar year 2024, and on Nov. 2 the Final Rule was published. The proposed rule included several proposals within the Quality Payment Program (QPP) that would impact vascular surgeons. The following article reviews highlights and the SVS responses.
One active area for CMS is the development of Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs). MVPs are viewed as the gateway for providers to transition into Alternative Payment Models (APMs). Their development for vascular conditions was covered in a recent Vascular Specialist article.
In the proposed rule for 2024, CMS proposed five new MVPs, which would bring the total to 12 optional MVPs for physician reporting. CMS also proposed to increase public comments during MVP development by soliciting feedback for 30 days following submission and making changes without input from the society or stakeholder that submitted the MVP if CMS deems those changes are appropriate. The agency also proposed to solicit recommendations for MVP updates annually. While the SVS appreciated CMS’ plan for public outreach, we argued that the persons and/or specialty societies who developed an MVP should be able to view and respond to public comments once received, as they will have a more nuanced view regarding how the proposed changes would impact the MVP and might create unintended consequences. The SVS also recommended that CMS provide a one-year lead time regarding the clinical areas under consideration for condition, specialty or procedure-based MVPs.
Subgroup reporting will become an option for MVP participants, which the SVS believes is important for broadening specialists’ reporting options and for the development of MVPs. The SVS emphasized the need for a transparent sign-on and a sufficient transition period for providers choosing to report via subgroups.
In the MIPS Quality Performance Category, CMS proposed maintaining the 30% weight of the final MIPS score but increasing the data completeness measure from 70% to 75% beginning with the 2024 performance year. The SVS noted that this increased reporting requirement was counter to CMS’ goals of reducing administrative burden within the MIPS program, particularly at a time when data and care integration are challenged and the costs of doing so are borne by physicians and their practices. Additionally, until more valid claims or easy-to-access electronic health measures are made available, it seems unfair to increase this requirement.
Under statute, the MIPS Cost Performance Category will continue to have a 30% weight. CMS proposed to establish a maximum cost improvement score of one point out of 100. The SVS recognized the flexibilities that CMS put in place to hold physicians harmless from undue MIPS penalties during the COVID-19 pandemic and asked that CMS continue to allow for hardship exemptions. The SVS also asked that CMS consider a maximum cost improvement score of at least five bonus points.
CMS proposed maintaining the 15% weight for the Improvement Activities (IAs) category and proposed four additions and five removals of IAs. The SVS encouraged development of methods for IA credit awards for performing activities that overlap with similar Quality, Cost and Promoting Interoperability (PI) measures.
CMS proposed that PI category remain at 25% of the overall MIPS score. CMS suggested requiring a yes/no response for Public Health and Clinical Data Exchange measures, with the requirement to submit level of active engagement. CMS also proposed to make the Query of Prescription Drug Monitoring Program (PDMP) a required measure. The SVS opposed the PDMP requirement, as many physicians and health systems remain incapable of interconnecting with PDMP systems. The SVS also strongly urged CMS to reconsider its proposal to tie physicians’ PI category success to the “all or nothing” approach proposed for Public Health and Clinical Data Exchange objective requirements.
There are many other components of the rule that cannot be covered here. For a more detailed review and/or the final SVS comment letter, visit the CMS Final Rule fact sheet at vascular.org/24FeeSkedFactSheet.
- Vascular Specialist June 2023 Volume 19 Number 06: vascular.org/June23VascularSpecialist
- Proposed rule: vascular.org/ProposedRulefor24
- SVS comment letter: vascular.org/2024PaymentPolicyResponse
- QPP Fact Sheet: vascular.org/2024QPPProposedRuleFactSheet
CAITLIN HICKS is vice chair and EVAN LIPSITZ the chair of the SVS Quality Performance Measures Committee.