Monday Morning Rounds with CMS

ICYMI, here is recent communication from CMS.

Events

2025 Self-Nomination and QCDR Measure Submission Question and Answer Session
When: Thursday, August 22, 2024 1:00 – 2:30 pm ET
Register for this event.

Participants can ask questions during this Q&A session about the Qualified Clinical Data Registry (QCDR) and Qualified Registry Self-Nomination and QCDR Measure Submission processes for the 2025 Merit-based Incentive Payment System (MIPS) performance period. Participants are also encouraged to ask questions regarding the QCDR and Qualified Registry Self-Nomination forms available on the Quality Payment Program (QPP) website as well as the QCDR Measure Submission process for those submitting QCDR measures.

News

Updated Resource: How to Test Electronic Health Care Transactions for HIPAA Compliance Fact Sheet
CMS’ National Standards Group, on behalf of HHS, has released an updated How to Test Electronic Health Care Transactions for HIPAA Compliance Fact Sheet (PDF), which provides an overview of how to test an electronic health care transaction in the Administrative Simplification Enforcement and Testing Tool (ASETT) for compliance with HIPAA Administrative Simplification standards. The fact sheet outlines the steps for testing a transaction, provides information on transactions and ASETT, and lays out where users can find additional support.

CY 2024 Medicare Promoting Interoperability Program eCQM Requirements
CMS would like to remind eligible hospitals and critical access hospitals (CAHs) participating in the Medicare Promoting Interoperability Program that they are required to report on a total of six electronic clinical quality measures (eCQMs) for the calendar year (CY) 2024 reporting period. This includes three self-selected eCQMs, plus the Safe Use of Opioids – Concurrent Prescribing measure, Severe Obstetric Complications measure, and the Cesarean Birth measure.

Quality Payment Program

APM Incentive Payments for 2024 Now Available; Learn if Action Needed
CMS recently posted details about the 2024 Advanced Alternative Payment Model (APM) Incentive Payments within the 2024 Learning Resources for QP Status and APM Incentive Payments Zip File (ZIP, 599KB) on the Quality Payment Program (QPP) Resource Library. This resource provides information about the amount of Advanced APM incentive payments that were paid to eligible clinicians this year based on their participation in Qualifying APM Participant (QP) Performance Period 2022. Additional information about APM Incentive Payments is available on the Federal Register in the “Alternative Payment Model (APM) Incentive Payment Advisory for Clinicians – Request for Current Billing Information for Qualifying APM Participants.”

Now Available: 2025 CMS QRDA III Implementation Guide (IG), Schematron, and Sample Files for Eligible Clinician Programs
CMS has published the 2025 CMS Quality Reporting Document Architecture (QRDA) Category III Implementation Guide (IG), Schematron, and Sample Files for Eligible Clinician Programs. The 2025 CMS QRDA III IG outlines requirements for Eligible Clinicians (EC) to report electronic clinical quality measures (eCQMs) for the calendar year (CY) 2025 EC quality reporting programs.

CMS Proposes Policy Changes for Quality Payment Program
CMS has issued its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP). The Notice of Proposed Rulemaking (NPRM) includes proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Now Available: Updated eCQM Data Element Repository (DERep) for CY 2025 Reporting and Performance Periods
CMS has updated the Electronic Clinical Quality Measure (eCQM) Data Element Repository (DERep) to provide information on eCQMs used in CMS quality reporting and incentive programs for the calendar year (CY) 2025 reporting and performance periods.

Upcoming MIPS Important Dates and Deadlines

CMS would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines:

October 2024

  • MIPS eligibility for the 2024 performance year will be updated based on the June 30 Alternative Payment Model (APM) snapshot (snapshot 2).
    • Note: Qualifying APM Participant (QP) determinations and MIPS APM participation information will be available on the QPP Participation Status Tool.
  • The 2025 virtual group election period opens, allowing solo practitioners and groups with 10 or fewer clinicians to submit an election to participate in MIPS as a virtual group for the 2025 performance period.
    • Note: 2025 virtual group election period details will be available on the QPP website later this year.
  • The final day to request a MIPS targeted review for your 2023 MIPS final score will be 60 days after the release of 2025 MIPS payment adjustment factor(s).
  • The exact date will be identified when we announce final performance feedback is available.
  • You’d only request a targeted review if you believe there’s an error in your MIPS performance feedback.

October 3, 2024

  • Last day to begin implementing an activity for a continuous 90-day performance period for the improvement activities performance category in the 2024 performance period.
    • Note: Most, but not all, improvement activities have a continuous 90-day performance period, but several improvement activities require completion of modules where there’s a year-long or alternate performance period. The performance period is 90 days unless otherwise stated in the activity description.

November 2024

December 2, 2024

  • Last day to register to report a MIPS Value Pathway (MVP) for the 2024 performance year.
  • Learn more about MVP registration.

December 2024

December 31, 2024

January 2, 2025

  • Data submission period opens for the 2024 performance year.

MIPS News

Administrative Simplification

CMS Innovation Center

CMS Innovation Center Seeks Input on New Proposals in CY 2025 PFS Proposed Rule
The CY 2025 Physician Fee Schedule (PFS) Proposed Rule released includes requests for information (RFIs) and proposals that would aim to increase accountable care relationships, reduce administrative burden, engage specialty providers in value-based care, and better align payment with quality measures. The PFS Proposed Rule is open for public comment until September 9, 2024.

CMS Innovation Center Announces Making Care Primary Model Participants
CMS is announcing the number of participating primary care organizations in the CMS Innovation Center’s Making Care Primary (MCP) Model. There are 133 participants in MCP, representing 772 practices across Colorado, Massachusetts, Minnesota, New Jersey, New Mexico, New York, North Carolina, and Washington. Fifty-five participants (41%) are Federally Qualified Health Centers (FQHCs), and 94 participants (71%) are small primary care organizations with 5 or fewer practices.

CMS Innovation Center Launches Guiding an Improved Dementia Experience Model, Announces Participants
The Centers for Medicare & Medicaid Services (CMS) is pleased to announce the launch of the Guiding an Improved Dementia Experience (GUIDE) Model, with almost 400 participating organizations building Dementia Care Programs (DCPs) serving hundreds of thousands of Medicare beneficiaries nationwide.