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Centers for Medicare & Medicaid Services Quality Payment Program
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* Upcoming MIPS Important Dates and Deadlines [ #link_1 ]
* 2024 MIPS Quality Measures Impacted by ICD-10 Coding Updates Effective October 1, 2024 [ #link_2 ]

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Upcoming MIPS Important Dates and Deadlines

The Centers for Medicare & Medicaid Services (CMS) would like to remind clinicians of important upcoming Merit-based Incentive Payment System (MIPS) dates and deadlines: 

*October 3, 2024*


* Last day to begin data collection for a continuous 90-day performance period for the improvement activities [ https://qpp.cms.gov/mips/improvement-activities ] performance category in the 2024 performance period. If you haven’t started your performance period for improvement activities, you must do so by no later than tomorrow, October 3. 
* *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. 

*October 11, 2024* 


* Final day to request a MIPS targeted review for your 2023 performance year feedback, including your MIPS final score and payment adjustment factor(s). Only submit a targeted review request if you believe there’s an error in your MIPS performance feedback. More information is available in the 2023 Targeted Review Guide (PDF, 1.4MB). [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2961/2023-Targeted-Review-Guide.pdf ]
* *Note:* CMS will only consider targeted review requests submitted by 8 p.m. ET. 

* Deadline to submit MIPS Extreme and Uncontrollable Circumstances (EUC) performance category reweighting requests for the 2023 performance year due to the Change Healthcare Cyberattack.

*October 2024*


* MIPS eligibility for the 2024 performance year will be updated based on the June 30 Alternative Payment Model (APM) snapshot [ https://qpp.cms.gov/apms/apm-determination-periods ].
* *Note:* Qualifying APM Participant (QP) determinations and MIPS APM participation information will be available on the QPP Participation Status Tool [ https://qpp.cms.gov/participation-lookup ].  

*December 2, 2024*


* Last day to register to report a MIPS Value Pathway (MVP) for the 2024 performance year. Learn more about MVP registration [ https://qpp.cms.gov/mips/mvps/learn-about-mvp-registration ].

*December 2024*


* MIPS eligibility for the 2024 performance year will be finalized following the release of the August 31 APM snapshot data. 
* QP determinations and MIPS APM participation information will be available on the QPP Participation Status Tool [ https://qpp.cms.gov/participation-lookup ].  

* Initial eligibility to participate in MIPS for the 2025 performance year will be released on the QPP Participation Status Tool [ https://qpp.cms.gov/participation-lookup ]. 

*December 31, 2024* 


* Last day of the 2024 performance year, after which clinicians will no longer be able to collect data for the year. 
* 2025 performance year virtual group election period [ https://qpp.cms.gov/mips/virtual-group-participation?py=2025 ] closes at 11:59 p.m. ET, after which prospective applicants will no longer be able to submit, revise, or retract their elections.
* QPP Exception Application window closes at 8 p.m. ET for MIPS eligible clinicians [ https://qpp.cms.gov/mips/how-eligibility-is-determined ] reporting traditional MIPS [ https://qpp.cms.gov/mips/traditional-mips ], an MVP [ https://qpp.cms.gov/mips/mips-value-pathways ], or the APM Performance Pathway (APP) [ https://qpp.cms.gov/mips/apm-performance-pathway ] who want to submit a MIPS EUC Exception Application [ https://qpp.cms.gov/mips/exception-applications?py=2024 ] or MIPS Promoting Interoperability Performance Category Hardship Exception Application [ https://qpp.cms.gov/mips/exception-applications?py=2024 ] for the 2024 performance year.   

*January 1, 2025*


* Payment adjustments based on the 2023 performance year go into effect.

*January 2, 2025*


* Data submission period opens for the 2024 performance year.

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2024 MIPS Quality Measures Impacted by ICD-10 Coding Updates Effective October 1, 2024

*What is the Policy for Identifying Impacted Quality Measures? *

The International Classification of Diseases, Tenth Revision (ICD-10) code updates are effective annually on October 1. However, the Merit-based Incentive Payment System (MIPS) quality measure specifications can’t be updated to account for such ICD-10 code updates until the next MIPS performance period.

In the Calendar Year (CY) 2018 Medicare Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) established an annual review process to identify and analyze MIPS quality measures that are significantly impacted by the ICD-10 coding changes during the performance period (82 FR 53714 through 53716 [ https://www.federalregister.gov/documents/2017/11/16/2017-24067/medicare-program-cy-2018-updates-to-the-quality-payment-program-and-quality-payment-program-extreme#page-53714 ]).

In the CY 2024 Medicare PFS Final Rule, the policy was amended to eliminate one of the criteria used to evaluate MIPS quality measures significantly impacted by ICD-10 coding changes during the annual review process. Specifically, the identification of measures that have changes to a minimum of 10% of ICD-10 codes; such criterion was replaced with a more general criteria that allows CMS to assess MIPS quality measures on a case-by-case basis to determine whether or not the ICD-10 coding change is significant (88 FR 79368 through 79369 [ https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other#p-5753 ]).

The criteria used to determine whether or not a MIPS quality measure is significantly impacted by ICD-10 coding changes are as follows: 


* Changes in measure scope or intent will be considered significant changes that affect the applicability of the historical benchmark. 

* Clinical guideline changes, new products, or procedures reflected in ICD-10 code updates. 

* Feedback on a measure received from measure developers and stewards. 

To determine if a MIPS quality measure is significantly impacted by ICD-10 code updates, we compare the ICD-10 codes listed in the posted 2024 measure specifications with the ICD-10 codes that were deleted or added during the annual ICD-10 code updates effective October 1 of the performance period.

If a MIPS quality measure is significantly impacted by ICD-10 coding changes, such a MIPS quality measure will be suppressed or truncated (the assessment of performance for the affected MIPS quality measure will be based on the first 9 months (January through September) of the 12-month performance period) for the 2024 performance period (42 CFR 414.1380(b)(1)(vii)(A) [ https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-414/subpart-O/section-414.1380#p-414.1380(b)(1)(vii)(A) ]).

Based on the analysis of the annual ICD-10 code updates, one MIPS quality measure (see Table 1 [ #Table1 ] below) is identified as being significantly impacted by ICD-10 coding changes and as a result, that MIPS quality measure will be truncated for the 2024 performance period.

Which Quality Measures are Impacted for the 2024 Performance Period? 

The following MIPS quality measure is identified as being significantly impacted for the 2024 performance period due to the annual ICD-10 code update.  

*Table 1: MIPS Quality Measure Identified for Truncation* 

*Quality ID # *



*Measure Title *



*Collection Type(s) *



*Measure Steward *



185 



Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use 



MIPS CQM 



American Gastroenterological Association 



 

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