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Nov 16 -- The Centers for Medicare & Medicaid Services (CMS), Health and Human Services (HHS), invites comments to OMB by December 18, 2023 regarding the Quality Payment Program (QPP)/Merit-Based Incentive Payment System (MIPS).

The Merit-based Incentive Payment System (MIPS) is a program for MIPS eligible clinicians that makes Medicare payment adjustments based on performance in the quality, cost, promoting Interoperability, and improvement activities performance categories. MIPS and Advanced Alternative Payment Models (AAPMs) are the two paths available for clinicians through the Quality Payment Program authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). As prescribed by MACRA, MIPS focuses on the following performance areas: quality – a set of evidence-based, specialty-specific standards; improvement activities that focus on practice-based improvements; cost; and use of certified electronic health record technology (CEHRT) to support interoperability and advanced quality objectives in a single, cohesive program that avoids redundancies.

Under the AAPM path, eligible clinicians may become Qualifying APM Participants (QPs) and are excluded from MIPS. Partial Qualifying APM Participants (Partial QPs) may opt to report and be scored under MIPS. APM Entities and eligible clinicians must also submit all of the required information about the Other Payer Advanced APMs in which they participate, including those for which there is a pending request for an Other Payer Advanced APM determination, as well as the payment amount and patient count information sufficient for us to make QP determinations by December 1 of the calendar year that is 2 years to prior to the payment year, which we refer to as the QP Determination Submission Deadline (82 FR 53886).  

The implementation of MIPS requires the collection of quality, Promoting Interoperability, and improvement activities performance category data. For the quality performance category, MIPS eligible clinicians, groups, and subgroups will have the option to submit data using various submission types, including Medicare claims, direct, log in and upload, and CMS-approved survey vendors. For the improvement activities and Promoting Interoperability performance categories, MIPS eligible clinicians, groups, and subgroups can submit data through direct, log in and upload, or log in and attest submission types. We finalized in the CY 2022 PFS final rule that a subgroup participating in MVP reporting will submit its affiliated group’s data for the Promoting Interoperability performance category, and in the scenario that a subgroup does not submit its affiliated group’s data, the subgroup will receive a zero score for the Promoting Interoperability performance category (86 FR 65413 through 65414).

As finalized in the CY 2021 PFS final rule (85 FR 84860), for clinicians in APM Entities, the APM Performance Pathway (APP) will be available for both ACOs and non-ACOs to submit quality data. Due to data limitations and our inability to determine who would use the APP versus the traditional MIPS submission mechanism for the CY 2024 performance period/2026 MIPS payment year, we assume ACO APM Entities will submit data through the APP, using the CMS Web Interface option, and non-ACO APM Entities would participate through traditional MIPS, thereby submitting as an individual or group rather than as an entity. We note that the CMS Web Interface is available as a collection type/submission type through the CY 2024 performance period/2026 MIPS payment year only for clinicians in Shared Savings Program reporting the APM Performance Pathway.

Beginning with January 1 of the CY 2023 performance period/2025 MIPS payment year, individual clinicians, groups, and APM Entities can choose to report the measures and activities in a MIPS Value Pathway (MVP). Beginning with the CY 2023 performance period/2025 MIPS payment year, clinicians can choose to participate as subgroups to report the measures and activities in an MVP. We note that the subgroup reporting option is not available for clinicians participating in traditional MIPS.

For the improvement activities performance category, we finalized changes to the improvement activities inventory for the CY 2024 performance period/2026 MIPS payment year and future years as follows: adding 5 new improvement activities; modifying 1 existing improvement activity; and removing 3 previously adopted improvement activities.

The implementation of MIPS requires the collection of additional data beyond performance category data submission. Additionally, there are information collections related to AAPMs. Please see sections 12 and 15 of this Supporting Statement for details.

We are requesting approval of 25 information collections associated with the CY 2024 PFS final rule as a revision to our currently approved information requests submitted under this package’s control number (OMB 0938-1314, CMS-10621). CMS has already received approval for the collection of information associated with the virtual group election process under OMB control number 0938-1343 (CMS-10652). CMS requested the approval for estimated burden related to the collection of information associated with the CAHPS for MIPS survey under OMB control number 0938-1222 (CMS-10450).

The changes in this CY 2024 collection of information request are associated with our November 16, 2023 (88 FR 78818) final rule (CMS-1784-F, RIN 0939-AV07).

Where updated data and assumptions were available for the CY 2024 PFS final rule, we have adjusted the applicable ICRs. We estimate a decrease in burden of 8,798 hours and $1,009,345 for the CY 2024 performance period/2026 MIPS payment year due to updated data and assumptions as well as policies finalized in the CY 2024 PFS final rule. As noted in section 8 of this Supporting Statement, we have updated our estimated burden submitted in the CY 2024 NPRM MIPS PRA package due to the availability of updated data for the CY 2024 performance period/2026 MIPS payment year.

As discussed in sections 12 and 15 of this Supporting Statement, the finalized policies in the CY 2024 PFS final rule will result in a decrease in burden for the ICRs related to the data submission via the Medicare Part B Claims, MIPS clinical quality measure (CQM), qualified clinical data registry (QCDR), and electronic clinical quality measure (eCQM) collection types for the quality performance category. The policies will also result in an increase in the burden for the ICRs related to the MVP quality performance category submission and MVP registration. The remaining changes to our currently approved burden estimates are adjustments due to the use of updated data sources and assumptions.

We are requesting to add two new ICRs, “simplified qualified registry self-nomination process” and “simplified QCDR self-nomination process,” to distinctly capture the burden for the number of QCDRs and qualified registries submitting applications for the simplified and full self-nomination process. We note that the addition of these ICRs is not due to the policy changes relevant to third party intermediaries in the CY 2024 PFS final rule.  It is a change in our approach to representing the estimated burden for the third-party intermediary self-nomination process due to availability of updated data.  

We are also requesting to remove one ICR, “nomination of Promoting Interoperability measures.”  We note that the removal of the ICR is not due to policy changes in the CY 2024 PFS final rule. It is due to a consistent decline in the number of submissions received for the ICR.  

QPP: https://qpp.cms.gov/
CMS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202311-0938-006 Click IC List for data collection instruments, View Supporting Statement for technical documentation. Submit comments through this webpage.
FRN: https://www.federalregister.gov/d/2023-24184

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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