Changes to Medicare quality reporting in 2024
Psychologists who see Medicare beneficiaries should be aware of reweighting changes made to the Merit-based Incentive Payment System for 2024, but there are still things you can do to ensure successful participation and prepare for the future.
Psychologists reporting under the Merit-based Incentive Payment System (MIPS) are reminded that beginning in 2024 CMS will no longer reweight the Promoting Interoperability (PI) category to zero for almost all nonphysician practitioners (NPPs). CMS will continue to reweight the PI category to zero for clinical social workers because they became eligible for MIPS reporting a few years after the other NPPs.
CMS adopted the reweighting policy several years ago after APA Services and other specialty societies pointed out that unlike physicians their members had not received financial incentives to adopt electronic health records technology and were not able to successfully report in this category. Automatic reweighting of the PI category to zero will continue for clinicians and groups who are:
- based in ambulatory surgical centers,
- based in facilities,
- providing non-face-to-face services, or
- small group practices (15 or fewer clinicians).
In 2024, the PI category reporting period increases from 90 to 180 continuous days per calendar year.
CMS is keeping some MIPS requirements in place for the coming year. The current minimum standards for performance (75 points) and data completeness (75%) will remain the same in 2024. Clinicians reporting under MIPS must have at least 75 points to avoid a negative adjustment in 2026 based on the 2024 reporting year. The maximum negative adjustment in 2026 will be -9%.
Many if not most psychologists are exempt from MIPS reporting under the low volume threshold (LVT). The LVT exemption applies to clinicians who in the past year:
- billed Medicare for $90,000 or less in allowable charges, or
- had 200 or fewer Medicare patients, or
- provided 200 or fewer Medicare services.
New 2024 quality measures of interest to psychologists include Improvement or Maintenance of Functioning for Individuals with a Mental and/or Substance Use Disorder (#504), Initiation, Review, And/Or Update To Suicide Safety Plan For Individuals With Suicidal Thoughts, Behavior, or Suicide Risk (#506), and Reduction in Suicidal Ideation or Behavior Symptoms (#507).
Some quality measures used by psychologists and other behavioral health providers are being removed in 2024. Adult MDD: Suicide Risk Assessment (#107) and Tobacco Use and Help with Quitting Among Adolescents (#402) are duplicative of newer measures. Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management (#283) has topped out its lifecycle while Follow-up After Hospitalization for Mental Illness (#391) is being removed due to attribution/burden, meaning associated costs could discourage providers from treating high risk patients.
Mental and Behavioral Health Registry (MBHR)
Since 2018, the MBHR has maintained its status as a CMS-approved Qualified Clinical Data Registry (QCDR), which enables Medicare-participating psychologists to easily track patient outcomes and meet the quality reporting requirements for participation in MIPS. For 2024, the MBHR will continue to contain specialty measures related to anxiety, PTSD, alcohol use, ADHD, psychosocial functioning, sleep, and cognitive assessment. Due to the ongoing efforts of our colleagues at the National Academy of Neuropsychology (NAN), including Drs. Nick Bott, Molly Colvin, Kari Eng, Maggie Lanca, and Jennifer Morgan, the MBHR has retained valuable measures that are specifically relevant to the specialty of neuropsychology. APA and NAN continue to advocate with CMS for the creation of a new neuropsychology MIPS Value Pathway, which would create an even more robust set of quality measures that are uniquely tailored to the complexities of neuropsychology service delivery.
What can you do to support psychologists’ success in the MIPS program?
- Use the MBHR registry to report for MIPS and select the QCDR Quality measures, including the four neuropsychology measures, to ensure that they receive benchmarks (which greatly impacts scoring) and to ensure that they aren’t removed due to lack of awareness/adoption.
- Vote for representatives from your state who will work to make changes to the federal law. CMS is bound by the 2015 Medicare Access and CHIP Reauthorization Act to implement the Quality Payment Program which includes MIPS.
- Provide responses to CMS through the public comment process on the annual proposed rule published each July.
