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Centers for Medicare & Medicaid Services Quality Payment Program. Small Practices Newsletter
Quality Payment Program Small Practices Newsletter: July 2024

The Quality Payment Program (QPP) Small Practices Newsletter is a monthly resource that provides small practices (15 or fewer clinicians) with program updates, upcoming QPP milestones, and resources to support their continued participation and success in QPP. We send this newsletter on the second Tuesday of each month. Please note this month’s newsletter was delayed to include information regarding the Medicare Physician Fee Schedule Proposed Rule released yesterday. 

Please share this newsletter with your fellow clinicians and practice staff and encourage them to sign up [ https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12879%2F&utm_source=newsletter&utm_medium=email&utm_id=newsletter_february2024&utm_content=smallpracsignup ] to receive this monthly resource.

*At-a-Glance: Required and Recommended Activities for Successful Participation in QPP *

Each month, we share required and recommended activities for small practices to support their successful participation in QPP. The activities follow a rolling quarter approach, letting you see activities for the previous month, the current month, and the following month.

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*In This Issue:                                                                                 *


* *Hot Topics: What You Need to Know*
* Merit-based Incentive Payment System (MIPS) Final Score Preview Period Is Now Open [ #link_1 ]
* Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule Released [ #link_2 ]
* 2024 MIPS Value Pathways (MVPs) Registration Open [ #link_3 ]
* 2024 MIPS Extreme and Uncontrollable Circumstances (EUC) Exception Application Available [ #link_4 ]
* New Resource Available: 2024 MIPS At-A-Glance Reporting Options for Small Practices [ #link_7 ]
* Relevant Small Practice Resources [ #link_5 ]
* Need Assistance? [ #link_6 ]

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Merit-based Incentive Payment System (MIPS) Final Score Preview Period Is Now Open

The MIPS Final Score Preview period for the 2023 performance year is now open. Small practices are strongly encouraged to sign in to the Quality Payment Program website [ https://qpp.cms.gov/login?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=qpplogin ] now to preview their final score based on data submitted for the 2023 performance year. 

Final Score Preview gives clinicians the opportunity to preview their 2023 final score, which will determine their 2025 MIPS payment adjustment. You should review your information to ensure there are no concerns with your 2023 performance feedback *_before_* we calculate payment adjustments. During the Final Score Preview, performance feedback will display data associated with the highest final score that *_could_* be attributed to the clinician and will include all the data required to calculate the final scores. 

Please note that scores can change between now and August if we identify any issues during Final Score Preview that require scoring updates. In addition, Final Score Preview *_won’t_ *include payment adjustment information. 

*What Action Do Small Practices Need to Take?* 

Clinicians and practice representatives are strongly encouraged to preview their final scores and performance feedback now and to contact the QPP Service Center [ #link_6 ] with any questions or concerns. Final Score Preview will enable us to review concerns and identify potential issues *_before_* we calculate payment adjustments. 

*When Will Final Performance Feedback Be Available?* 

We anticipate that final performance feedback, including your final score and 2025 MIPS payment adjustment, will be available in August 2024. * *

*Additional Resources* 


* 2023 Final Score Preview FAQs (PDF, 3MB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2905/2023MIPSFinalScorePreviewFAQs.pdf ]
* 2023 Final Score Preview Supplemental Reports Guide (PDF, 824KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2914/2023-MIPS-Performance-Feedback-Supplemental-Reports-Guide.pdf ]

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Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule Released

*CMS Proposes Policy Changes for QPP*

The Centers for Medicare & Medicaid Services (CMS) issued its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking [ https://www.federalregister.gov/public-inspection/2024-14828/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule ], which includes proposed policies for QPP. 

The Notice of Proposed Rulemaking (NPRM) includes proposals for MIPS and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Specifically, we’re proposing policies that:


* Continue the development and maintenance of MVPs
* Establish the APM Performance Pathway (APP) Plus quality measure set.
* Update the MIPS measure/activity inventories and scoring methodologies.

Finally, we’re proposing a small number of policies intended to maintain stability within the MIPS program through the established performance threshold and data completeness criteria.

*2025 Policy Highlights*

Key QPP policies that we’re proposing in the 2025 PFS Proposed Rule include:


* Introducing *6 new MVPs for the 2025 performance period* that are related to ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care.
* Creating APP Plus, an *additional quality measure set under the APP,* which would include the 6 measures currently in the APP quality measure set and incrementally incorporate the remaining 5 Adult Universal Foundation quality measures (for a total of 11 measures by the 2028 performance period/2030 payment year).
* *Maintaining the current performance threshold policies*, leaving the performance threshold at *75 points* for the 2025 performance period.
* *Keeping the 75% data completeness criteria* through the 2028 performance period.

*Overview of RFIs*

We’re also seeking feedback on RFIs about the following topics:


* MVP adoption and subgroup participation
* Public Health and Clinical Data Exchange Objective under the Promoting Interoperability performance category
* Guiding principles for the development of patient-reported outcome quality measures
* Changes to the administration of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey

*Comment Submission Period*

CMS encourages you to submit comments on these proposals.

You must officially submit your comments in one of the following ways: 


* *Electronically* – You may submit electronic comments through regulations.gov [ https://www.regulations.gov/ ].
* *Regular mail* – You may mail written comments to the following address ONLY: 

Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1807-P, P.O. Box 8016, Baltimore, MD 21244-8016. *Please allow sufficient time for mailed comments to be received prior to the end of the comment period.* 


* *Express or overnight mail* – You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1807-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

*Please note:* FAX transmissions won’t be accepted. 

The 60-day comment period for the 2025 PFS Proposed Rule is open until 11:59 PM ET on September 9, 2024.

*For More Information*

Learn more about the QPP proposals by reviewing the following Quality Payment Program policies in the CY 2025 Medicare PFS Proposed Rule Resources:


* 2025 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2876/2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf ] –Provides an overview of QPP proposals and RFIs included in the CY 2025 Medicare PFS Proposed Rule, and a comparison table contrasting existing policies with proposals.
* 2025 Proposed and Modified MVPs Guide [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2877/2025-Proposed-and-Modified-MVPs-Guide.pdf ] – Highlights newly proposed MVPs and modifications to previously finalized MVPs, beginning with the 2025 performance year.

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2024 MIPS Value Pathways (MVPs) Registration Open

MVPs [ https://qpp.cms.gov/mips/mips-value-pathways?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=mvps ] are the newest way to meet MIPS reporting requirements. To offer more meaningful participation in MIPS, each MVP includes a subset of measures and activities related to a specialty or medical condition. Registration is open through *December 2, 2024, at 8 p.m. ET*.

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2024 MIPS Extreme and Uncontrollable Circumstances (EUC) Exception Application Available

This is a reminder that the MIPS EUC Exception Application [ https://qpp.cms.gov/mips/exception-applications?py=2023&utm_source=newsletter&utm_medium=email&utm_campaign=july2023&utm_content=2023eucapp ] is available for the 2024 performance year. Applications can be submitted until *8 p.m. ET on December 31, 2024*. 

*When Would a Small Practice Submit* *a MIPS EUC Exception Application?*

MIPS eligible clinicians, groups, and virtual groups may apply to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances. Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances must: 


* Cause you to be unable to collect information necessary to submit data for a MIPS performance category.
* Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (e.g., if you were unable to collect data for the quality performance category for 3 months).
* Impact your normal process, affecting your performance on cost measures and other administrative claims measures.

*How Do I Apply for a MIPS EUC Exception Application?* 

You must have a Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself or another MIPS eligible clinician, group, virtual group, subgroup, or Alternative Payment Model (APM) Entity. For more information on HARP accounts, please refer to the “Register for a HARP Account” document in the QPP Access User Guide (ZIP, 4 MB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/335/QPP%20Access%20User%20Guide.zip?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=accessuserguide ]. 

You’ll need to sign in to the Quality Payment Program website [ https://qpp.cms.gov/?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=qppwebsite ] with your HARP credentials.


* Once you’ve signed in, select “Exceptions Applications” on the left-hand navigation pane.
* Select “Add New Exception.”
* Select “Extreme and Uncontrollable Circumstances Exception.”

*How Do I Know If I’m Approved?* 

You’ll receive an email to let you know whether your request is approved or denied. You can also check the status of your application by signing in to the Quality Payment Program website [ https://qpp.cms.gov/?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=qppwebsite ] and navigating to “Exceptions.” If your request is approved, this information will also be added to your eligibility profile in the QPP Participation Status Tool [ https://qpp.cms.gov/participation-lookup?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=qpplookup ] on a rolling basis. If your application is approved at the end of the performance year, it may not appear in the QPP Participation Status Tool until the submission window opens on *January 2, 2025*. 

*_Reminder_**:* Although the MIPS Promoting Interoperability Performance Category Hardship Exception Application is available now, small practices qualify for automatic reweighting. This means that small practices don’t need to submit a hardship exception application. 

Small practices can still choose to submit Promoting Interoperability data, which would void reweighting f the performance category. We’ll score any data that’s submitted. Please visit the Promoting Interoperability: Traditional MIPS Requirements webpage [ https://qpp.cms.gov/mips/promoting-interoperability?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=pi ] to learn more about the reporting requirements.

*For More Information* 


* Visit the QPP Exception Applications [ https://qpp.cms.gov/mips/exception-applications?py=2023&utm_source=newsletter&utm_medium=email&utm_campaign=july2023&utm_content=2023eucapp ] webpage for more information and a link to the application.
* Download the 2024 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide (PDF, 1 MB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2845/2024-MIPS-EUC-Exception-Application-Guide.pdf ] in the QPP Resource Library [ https://qpp.cms.gov/resources/resource-library?utm_source=newsletter&utm_medium=email&utm_id=newsletter_july2023&utm_content=qppresourcelibrary ].

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New Resource Available: 2024 MIPS At-A-Glance Reporting Options for Small Practices

The 2024 MIPS At-A-Glance Reporting Options for Small Practices [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2929/2024-MIPS-At-A-Glance-Reporting-Options-for-Small-Practices.pdf ] resource provides a high-level comparison of the 3 MIPS reporting options for MIPS eligible clinicians in small practices.

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Relevant Small Practice Resources

*2024 Small Practice Resources*

2024 What’s New for Small Practices (PDF, 787 KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2657/2024What%27sNewforSmallPractices.pdf?utm_source=newsletter&utm_medium=email&utm_campaign=february+2024&utm_id=newsletter_february2024&utm_content=24whatsnewsp ]

2024 MIPS Quick Start Guide for Small Practices (PDF, 1 MB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2622/2024MIPSGuideforSmallPractices.pdf?utm_source=newsletter&utm_medium=email&utm_campaign=february+2024&utm_id=newsletter_february2024&utm_content=24mipsguidesp ]

MIPS 2024 Small Practice Eligibility and Participation FAQs (PDF, 461 KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2729/2024-Small-Practice-Eligibility-FAQs.pdf ]

Do I Need to Participate in MIPS? How to Check Eligibility Status (VIDEO) [ https://www.youtube.com/watch?v=rHoH4hJaetI ]

Small Practices FAQs [ https://qpp.cms.gov/resources/small-underserved-rural-practices#:~:text=Service%20Center%20Ticket-,FAQs,-Am%20I%20eligible ] [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2657/2024What%27sNewforSmallPractices.pdf?utm_source=newsletter&utm_medium=email&utm_campaign=february+2024&utm_id=newsletter_february2024&utm_content=24whatsnewsp ]

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Need Assistance?

Contact the QPP Service Center by email at QPP@cms.hhs.gov, by creating a QPP Service Center ticket [ https://cmsqualitysupport.servicenowservices.com/ccsq_support_central?utm_source=newsletter&utm_medium=email&utm_id=newsletter_september2023&utm_content=ccsqsupport ], or by phone at 1‑866‑288‑8292 (Monday – Friday, 8 a.m. – 8 p.m. ET).

People who are deaf or hard of hearing can dial 711 to be connected to a Telecommunications Resource Service (TRS) Communications Assistant.

QPP Footer 2023 [ https://qpp.cms.gov/resources/help-and-support ]


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