With each passing Performance Year (PY), the Centers for Medicare and Medicaid Services (CMS) makes adjustments to the Merit-Based Incentive Payment System (MIPS). Changes include which measures are available to clinicians, and how their scores are evaluated. This year, with the expiration of the COVID-19 Extreme and Uncontrollable Circumstance (EUC) hardship exception, it’s a good time to do a mid-year check in.
What is the Same?
Most general aspects of the MIPS program will remain the same, the most significant being the Performance Threshold. The performance threshold will remain 75 points. This means that a final score of 75 will still result in a neutral payment adjustment for payment year 2026. In order to qualify for 2026 payment adjustment, the MIPS final score must exceed 75 points. The following table shows the adjustment plan for 2024:
| 2024 MIPS Final Score | 2026 Payment Adjustment |
| 0 – 18.75 points | -9% |
| 18.76 – 74.99 points | Greater Than –9%, Less than 0% |
| 75 points | 0% |
| 75.01 – 100 points | Greater than 0%, Less than or Equal to +9% |
Changes from PY23 to PY24
MVPs (MIPS Value Pathways)
- The number of available MVPs clinicians can report on has increased from 12 in 2023, to 16 in 2024.
- You can read about how to report MVPs for PY24 by reading our blog post.
Quality Category
- In 2023, clinicians were required to achieve 70% data completeness for each quality measure. In 2024, you are required to achieve 75% data completeness.
- The number of available quality measures remains the same at 198, but modifications were made:
- Addition of 11 new quality measures
- Complete removal of 11 quality measures
- Partial removal of 3 quality measures (retained for MVP use only)
- Substantive changes to 58 existing quality measures.
Improvement Activities (IA) Category
- The number of available Improvement Activities has increased from 104 in 2023, to 106 in 2024
- Addition of 5 new improvement activities
- Removal of 3 improvement activities
- Modification of 1 existing improvement activity
Promoting Interoperability (PI) Category
- The performance period for the PI category has been changed from 90 continuous days in 2023, to 180 continuous days in 2024.
- Clinicians are now required to attest “yes” for the SAFER Guide measure.
- Automatic reweighting for the PI category has been altered for some clinician types, with some types being disqualified for reweighting, and others gaining qualification. The following chart shows which types are being altered:
| Now Disqualified | Still Qualified |
| Physical Therapists | Clinical Social Workers |
| Occupational Therapists | ASC-Based Clinicians and Groups |
| Qualified Speech-Language Pathologists | Hospital-Based Clinicians and Groups |
| Clinical Pathologists | Non-Patient Facing Clinicians and Groups |
| Registered Dieticians or Nutrition Professionals | Clinicians in a Small Practice |
Cost Category
- CMS is updating the way they calculate the Cost category for PY24, specifically to match the scoring methodology of the Quality category.
- There will be a total of 29 Cost measures available in 2024, including the addition of 5 new episode-based measures.
With the many changes ahead, participants are urged to gain clarification to ensure how this impacts their reporting. Most at risk are the practices that had utilized the COVID-19 Extreme and Uncontrollable Circumstance (EUC) hardship exception as it has now expired.
You can view our latest on-demand webinar discussing ‘MIPS in a Post-COVID EUC World’ to learn more about 2024 MIPS, and what clinicians should be doing differently for this year’s submission. You can also schedule a free 15-minute consultation with one of our MIPS experts here.