MIPS 2023: Reporting for Pathologists

August 9, 2022

By: Beth Madden, Client Administrator

CMS has announced what lies ahead for the Merit-based Incentive Payment System (MIPS) program with proposed adjustments for the 2023 performance year, which impacts Medicare Part B payments in 2025.

The agency said it is focusing on continuing development of MVPs, or MIPS Value Pathways. Considered a “subgroup participation option,” MVPs allow specialty groups to do their MIPS reporting in specialty specific groups and include specialty specific quality and improvement measures. For PY2023, these MVPs include Anesthesia, Chronic Disease Management, Emergency Medicine, Heart Disease, and others. What does it mean for you since Pathology is not on the list?

For now, business as usual. CMS is proposing the performance threshold remain at 75 to avoid a penalty. Performance Year 2023 is the first year where there will not be an exceptional performance threshold bonus. With the possibility of a bonus now off the table, the main goal is to avoid a penalty. The proposed payment adjustments for 2025 are:

Credit: CMS

We will not see any changes in the category weights for 2023, so they will remain as indicated below:

  • Quality: 30% of MIPS Score (40% for small practices)
    • CMS is proposing a change in the Measure Scoring:  Large practices (>15 clinicians), remove the 3-point floor for measures meeting data completeness and case minimum. These measures would be scored on a 1–10-point scale instead of a 3–10-point scale.  No change for small practices, with the 3-point floor remaining.
  • Cost: 30% of MIPS Score
    • No significant changes proposed
  • Improvement Activities: 15% of MIPS Score (30% for small practices)
    • While there are no, current, significant changes proposed for scoring or reporting in this category, there are several proposes changes to the list of improvement activities including for new proposed activities.
  • Promoting Interoperability: 25% of MIPS Score (N/A for small practices)

It remains enormously frustrating to be in a specialty this program is not designed to support. We continue to advise clients to work with a pathology specialty registry to have the best chance at avoiding a penalty. We also encourage clients to consider a hardship exception application to opt-out of MIPS in 2023 if they qualify.

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