Compliance Series: What Does Anesthesia Need to Know About MIPS in 2024?

By Lance Mueller
Director of Healthcare Quality

Participating in the MIPS program in 2024 requires groups and clinicians to consider their Return On Investment (ROI) carefully. To ensure you get the best ROI, you should evaluate your MIPS eligibility, identify any extreme and uncontrollable circumstances, and maximize your performance in the categories you must report.

Eligibility

Most Anesthesia clinicians are not required to report for MIPS since they do not meet the low-volume threshold (LVT). If you fall below the LVT requirement, you will not receive a payment adjustment, positive or negative. According to CMS, you must participate in MIPS (unless you are exempt) if, in both 12-month segments of the MIPS Determination Period, you:

  • Bill over $90,000 for Medicare Part B covered professional services; 
  • See more than 200 Medicare Part B patients; 
  • Provide more than 200 covered professional services to Medicare Part B patients. 

Visit the Quality Payment Program site for more on how MIPS Eligibility is Determined.

CMS uses two 12-month MIPS determination periods to determine your MIPS eligibility for the performance period (calendar year). CMS will provide the first Lookup for 2024 in December 2023, while the second Lookup will be available in December 2024. If you don’t qualify for the first Lookup, you don’t need to report individually in 2024. However, you can still report as part of a group.

Extreme and Uncontrollable Circumstance (EUC) Waivers

In recent years, CMS has granted automatic waivers for Extreme and Uncontrollable Circumstances (EUC). In 2022, almost all applicants who applied for an EUC were granted waivers. However, for 2024, CMS has indicated that they will be less lenient with these waivers. According to CMS, MIPS-eligible clinicians, groups, and virtual groups can request to reweigh any MIPS performance categories if they have been affected by extreme and uncontrollable circumstances. You can find more information about this on the CMS website. 

Also, CMS may automatically grant EUCs to clinicians located in areas affected by events, such as FEMA-designated major disaster areas. Following CMS or your medical specialty association for more details about automatic EUCs is advisable.

Performance Categories

CMS measures your performance across the following four categories:

Cost – CMS calculates your measures based on your Medicare claims. Few anesthesia providers/groups have any Cost measures – reweighted to Quality.

Promoting Interoperability (PI) – Promotes patient engagement and use of EHRs. Most anesthesia groups/providers are considered non-patient-facing. As such, CMS reweighs PI to Quality.

Improvement Activities – Asses how you improve the care you provide to patients and their families. Simple attestation to CMS that you did the activity.

Quality – Assess the Quality of care you deliver based on performance measures approved by CMS.

For Anesthesia, we recommend the following measures:

  • #130 – Current Medications
  • #404 – Smoking Abstinence
  • #424 – PeriOperative Temperate Management
  • #430 – Prevention of PONV – Adults
  • #463 – Prevention of POV – Pediatrics
  • #477 – MultiModal Pain Management
  • ABG#44 – Low-Flow Inhalational General Anesthesia
  • AQI#65 – Avoidance of Cerebral Hyperthermia in CPB
  • AQI#72 – PeriOp Anemia Management in Total Joint Procedures

Here are three tips to help you maximize your MIPS reporting in 2024:

  1. Report as a group for Traditional MIPS and MIPS Value Pathways (MVPs). Also, report all MIPS Eligible Clinicians for Traditional MIPS and MVPs. If the group gets a negative payment adjustment, only report the MIPS ECs. Any MIPS ECs you report will get a higher group or individual score.
  2. Report more than the required six quality measures. CMS will score all quality measures you report and count the highest six.
  3. Monitor your performance feedback monthly and implement corrective actions at the group, facility, and individual levels where needed. It’s easier to fix issues early than to face an emergent situation later in the year or during data submission.

Want more MIPS Tips? Check out our 2024 Anesthesia MIPS Tip Sheet.

Don’t hesitate to contact Lance Mueller, Director of Healthcare Quality at Ventra Health, with questions. Email: lance.mueller@ventrahealth.com

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What’s Next and How Ventra Health Can Help

Ventra Health takes compliance very seriously. The guidelines put forth by various regulating bodies, while sometimes complicated or inconvenient, are critical to follow closely. Our Provider Education team has launched this Compliance Blog Series to help you navigate the complexities of compliance and coding changes.

In case you missed it, check out our other posts in the series:

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