Background

The Medicare Access and CHIP Reauthorization Act of 2015— also known as MACRA—was signed into law on April 16, 2015. This law, which created the Quality Payment Program (QPP), changed the way physicians are paid for providing services under Medicare. It continued the move away from fee-for-service payment, toward value-based payment approaches that endeavor to pay clinicians based on the quality, value, and outcomes of the care they provide.

Clinicians can participate in the QPP via two separate tracks: the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs).

 

 

(Source: U.S. Centers for Medicare & Medicaid Services)

With MIPS, clinicians earn payment adjustments (either bonuses or penalties) for Part B covered professional services, based on four performance categories: 

• Quality
• Cost
• Improvement activities related to care processes, access, and patient engagement
• Promoting interoperability, which focuses on the use of certified electronic health record technology (CEHRT).

 

 

(Source: U.S. Centers for Medicare & Medicaid Services)

For 2024, clinicians who are eligible to participate in MIPS can report via one of three options:

• Traditional MIPS (the original reporting option)
• APM Performance Pathway (APP) [available only to clinicians who participate in a MIPS APM]
• MIPS Value Pathways (MVPs)

MVPs are the newest reporting option.  Each MVP includes a subset of measures and activities that relate to a specific specialty or medical condition.  In the next few years, CMS plans to make MVP reporting mandatory for many MIPS participants and sunset Traditional MIPS.

The 2024 MIPS performance year spans from January 1-December 31, and data collected for this timeframe must be reported to CMS by March 31, 2025. Payment adjustments based on 2024 performance will be made in 2026.

This toolkit focuses on 2024 participation rules, performance categories, and scoring approaches for Traditional MIPS reporting.  A separate MVP Toolkit explains the MVP reporting option in detail and describes the two MVPs that are supported by the AQUA Registry in 2024 (i.e., the Advancing Cancer Care MVP and the Focusing on Women’s Health MVP).

Participation in MIPS

Physicians, physician assistants, and nurse practitioners are among the types of clinicians who can participate in MIPS. The QPP Participation Status Lookup Tool, provided by CMS, allows providers to view their MIPS eligibility status.

A clinician is required to participate in MIPS (i.e., is MIPS-eligible) if he/she is an eligible clinician type and meets all of the following criteria:

• Has enrolled as a Medicare provider before January 1, 2024
• Is NOT a Qualifying Participant in an Advanced APM
• Meets all the following low-volume threshold criteria:
  • Sees more than 200 Medicare Part B patients
  • Performs 200 or more covered professional services to Part B patients
  • Has $90,000 or more in Medicare Part B covered professional services

If a clinician does not meet the eligibility requirements due to the low-volume threshold criteria, but meets at least one of those three criteria, he/she can opt-in to MIPS or voluntarily report. To opt-in, clinicians must log onto the QPP portal and register to opt-in.

Those selecting this option will then be subject to applicable payment adjustments (positive or negative). In contrast, those who voluntarily report gain reporting experience, receive performance feedback, and become eligible to have performance data published on Medicare’s Care Compare. However, they are not subject to payment adjustments, and their performance results will not be included in MIPS measure benchmark calculations.

Options for Participation

Providers may be eligible to report as an individual clinician, as part of a group, as part of a virtual group, or as an APM entity.

• Those reporting as an individual are scored independently on the data they submit to CMS.
• Those reporting as a group submit data on measures and activities based on the aggregated performance of clinicians who are billing under a Taxpayer Identification Number (TIN).
  • More specifically, CMS defines a group as a single TIN with 2 or more clinicians (as identified by their National Provider Identifier (NPI), who have reassigned their Medicare billing rights to that TIN.
  • At least one clinician within the group must be MIPS-eligible.
  • The TIN’s payment adjustment will be based on the group’s final score from the MIPS performance categories.
  • If someone wishes to submit data for both individual and group reporting, CMS will analyze both sets of data and use the option with the higher score.
• Clinicians may also form virtual groups.
  • These must be approved by CMS, and those interested in participating in MIPS via this option must register with CMS prior to the reporting year.
  • More information on the virtual group option is provided on the CMS QPP website. The AQUA Registry does not support virtual groups.
• An APM Entity is composed of all eligible clinicians participating with an APM Entity at certain times during the year.
  • CMS defines an APM Entity as one that participates in an Alternative Payment Model or other payer arrangement through a direct agreement with CMS or other payer, or through Federal or State law or regulation.
  • Note that the performance categories are weighted differently for the APM Entity option compared with how they are weighed for the individual, group, and virtual options.
  • Additional information is provided on the CMS QPP website.

Performance Category Weights, Scoring, and Payment Impact

Performance category weights vary based on the participation option (i.e., weights for individual, group, and virtual group participation vs. APM Entity participation).  Weights also vary for small practices that did not submit PI data or when re-weighting is applied (e.g., due to hardship exemptions or extreme and uncontrollable circumstances). In this toolkit, weights for the individual, group, and virtual group participation options are shown.

In 2024, weights for the individual, group, and virtual group participation options are as follows:

• Quality: 30 percent
• Cost: 30 percent
• Improvement Activities (IAs): 15 percent
• Promoting Interoperability (PI): 25 percent

 

(Source: U.S. Centers for Medicare & Medicaid Services)

CMS scores each performance category separately, then adds them together to get a final score. Performance categories may be reweighted in certain circumstances (e.g., for small practices, for approved extreme and uncontrollable circumstances).

The performance threshold for 2024 remains 75 points.

• Participants must achieve 75 points to avoid a negative payment adjustment (penalty).
• Those who do not participate will incur a 9 percent penalty on their 2026 Part B Medicare payments, and those falling between zero and <75 points will face a penalty.
• Those scoring more than 75 points will receive a positive payment adjustment (bonus).

MIPS is a budget neutral program, meaning the penalties must pay for the bonuses.  Thus, the amount available for bonus payments will be determined once CMS determines penalty amounts.  CMS no longer offers an exceptional performance bonus. 

Performance Category: Quality 

(Source: U.S. Centers for Medicare & Medicaid Services)

The Quality performance category focuses on measures that assess health care processes, outcomes, and patient experiences of care. For this performance category, participants must report data for at least 6 quality measures (one of which must be an outcome measure, or a high-priority measure, in the absence of an applicable outcome measure) or a complete specialty measure set (if the set has less than 6 measures). Participants can opt to report on more than six measures; in that case, CMS will use the 6 measures with the highest scores. In 2024, the weight for the Quality performance category for the individual, group, and virtual group participation options is 30 percent (that is, this category accounts for 30% of the total MIPS score).

Data Collection Types

There are several different ways that measures can be collected and reported for MIPS. In 2024, participants may use a combination of any of these options to complete their MIPS reporting. The possible reporting options for each specific measure are listed in the measure specifications.

A Qualified Clinical Data Registry (QCDR) is a CMS-approved entity (such as a registry, certification board, specialty society, etc.) that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care furnished to patients. Individuals and groups may report via a QCDR. The AUA offers its own QCDR, the AQUA Registry. For more information, contact 855-898-AQUA (2782) or AQUA@AUAnet.org.

Medicare Part B Claims reporting has traditionally been used by many urologists. However, this option may be used only by those who are members of a practice with 15 or fewer providers. This reporting option involves submitting extra CPT Category II codes (also known as Quality Data Codes or G codes) along with regular billing CPT codes and diagnosis codes on electronic or paper claims submitted to Medicare. Medicare then forwards these claims files to the processor.

MIPS Clinical Quality Measures (CQM) reporting may be used by both individuals and groups. It is accomplished by contracting with a CMS-approved data processing service that can compile patient data and generate reports on a provider’s or practice's behalf directly to the MIPS processor. Depending on the vendor, data can be transferred to the registry in several ways.

Electronic Clinical Quality Measures (eCQM) reporting involves either submitting one’s data directly to CMS or to a vendor who will then submit it to CMS on the provider or practice’s behalf. Check with your EHR vendor to find out what option(s) is available to you. Both individuals and groups may use EHR reporting.

The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey is an optional measure for participating groups reporting through the MIPS program. The CAHPS for MIPS Survey measure is a patient experience measure; note that there are beneficiary sampling requirements for this measure. The survey must be administered by a CMS-approved vendor. Participants must register between April 1, 2024, and July 1, 2024, to administer the CAHPS for MIPS Survey measure.

Available Quality Measures

There are 199 individual measures (sometimes called “QPP measures” or “MIPS measures”) to consider for MIPS reporting in 2024, in addition to the 8 urology-specific measures that are available through AUA’s AQUA registry. Of these 207 measures, 44 are supported through the AQUA registry (for some of these, both CQM and eCQM versions are supported, bringing the total number of measures supported through AQUA to 56).

In order to help urologists identify relevant measures, CMS created a Urology Measure Set (note that the 8 AUA urology-specific measures are not included on this list, as they are reportable only through participation in the AQUA registry). If participants select 6 measures from this list, at least one must be an outcome measure or a high priority measure (in the absence of an applicable outcome measure).

Regardless of which measures are selected, a participant must report 75 percent of the applicable patients for any measure (with a minimum of 20 applicable patients). If this reporting threshold is not met, participants will receive a score of 0 for the measure (unless the participant belongs to a practice with 15 or fewer providers; if so the participant will receive 3 points for the measure).

CMS gauges how well participants score on each reported measure and assigns a point total.  The AUA recommends that participants consider the following when selecting and reporting measures:

• Clinical conditions treated
• Practice improvement goals
• Current quality improvement efforts Quality information already being reported to other payers or entities
• Effects of measure reporting on overall MIPS score Need for reporting to achieve measure benchmarks

The score for the Quality category is based on the sum of the points for the six highest-scoring measures. To ensure that CMS continues to include urology-relevant measures in the MIPS program, participants should not limit reporting to six measures only but instead, report on as many relevant measures as possible, per the above considerations.

Quality Measures Supported Through the AQUA Registry

The 56 measures available through the AQUA registry are listed below. The specifications for the Non-QPP Measures and QPP Measures can be found on the AQUA Registry and CMS QPP website.

AQUA Urology Specific Measures (Non-QPP Measures)

• AQUA8 – Hospital Admissions or Infectious Complications within 30 days of Prostate Biopsy [QCDR]
• AQUA14 – Stones: Repeat Shock Wave Lithotripsy (SWL) Within 6 Months of Initial Treatment [QCDR]
• AQUA15 – Stones: Urinalysis or Urine Culture Performed Before Surgical Stone Procedures [QCDR]
• AQUA16 – Non-Muscle Invasive Bladder Cancer: Repeat Transurethral Resection of Bladder Tumor (TURBT) for T1 disease [QCDR]
• AQUA26 – Benign Prostate Hyperplasia (BPH): Inappropriate Lab & Imaging Services for Patients with BPH [QCDR]
• AQUA35 – Non-Muscle Invasive Bladder Cancer: Initial Management/Surveillance for Non-Muscle Invasive Bladder Cancer [QCDR]
• AQUA36 – Prostate Cancer: Confirmation Biopsy in Newly Diagnosed Patients on Active Surveillance [QCDR]
• MUSIC4 – Prostate Cancer: Active Surveillance/Watchful Waiting for Newly-Diagnosed Low-Risk Prostate Cancer Patients [QCDR]

QPP Measures

• Measure #1 – Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) [MIPS CQM, eCQM, Claims]
• Measure #47 – Advance Care Plan [MIPS CQM, Claims]
• Measure #48 – Urinary Incontinence: Assessment of Presence or Absence of Urinary Incontinence in Women Aged 65 Years and Older [MIPS CQM]
• Measure #50 – Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older [MIPS CQM]
• Measure #102 – Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients [MIPS CQM, eCQM]
• Measure #104 – Prostate Cancer: Combination Androgen Deprivation Therapy for High Risk or Very High Risk Prostate Cancer [MIPS CQM]
• Measure #130 – Documentation of Current Medications in the Medical Record [MIPS CQM, eCQM]
• Measure #134 – Preventive Care and Screening: Screening for Depression and Follow-Up Plan [MIPS CQM, eCQM, Claims]
• Measure #143 – Oncology: Medical and Radiation – Pain Intensity Quantified [MIPS CQM, eCQM]
• Measure #144 – Oncology: Medical and Radiation – Plan of Care for Pain [MIPS CQM]
• Measure #226 – Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention [MIPS CQM, eCQM, Claims]
• Measure #236 – Controlling High Blood Pressure [MIPS CQM, eCQM, Claims]
• Measure #238 – Use of High Risk Medication for Older Adults [MIPS CQM, eCQM]
• Measure #317 – Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented [MIPS CQM, eCQM, Claims]
• Measure #318 – Falls: Screening for Future Fall Risk [eCQM]
• Measure #357 – Surgical Site Infection (SSI) [MIPS CQM]
• Measure #358 – Patient-Centered Surgical Risk Assessment and Communication [MIPS CQM]
• Measure #370 – Depression Remission at Twelve Months [MIPS CQM, eCQM]
• Measure #374 – Closing the Referral Loop: Receipt of Specialist Report [MIPS CQM, eCQM]
• Measure #422 – Performing Cystoscopy at the Time of Hysterectomy for Pelvic Organ Prolapse to Detect Lower Urinary Tract Injury [MIPS CQM, Claims]
• Measure #431 – Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling [MIPS CQM]
• Measure #432 – Proportion of Patients Sustaining a Bladder Injury at the Time of any Pelvic Organ Prolapse Repair [MIPS CQM]
• Measure #433 – Proportion of Patients Sustaining a Bowel Injury at the Time of any Pelvic Organ Prolapse Repair [MIPS CQM]
• Measure #453 – Percentage of Patients who Died from Cancer Receiving Systemic Cancer-Directed Therapy in the Last 14 Days of Life (lower score – better) [MIPS CQM]
• Measure #457 – Percentage of Patients who Died from Cancer Admitted to Hospice for Less than 3 Days (lower score – better) [MIPS CQM]
• Measure #462 – Bone Density Evaluation for Patients with Prostate Cancer and Receiving Androgen Deprivation Therapy [eCQM]
• Measure #476 - Urinary Symptom Score Change 6-12 Months After Diagnosis of Benign Prostatic Hyperplasia [eCQM]
• Measure #481 – Intravesical Bacillus-Calmette Guerin for Non-muscle Invasive Bladder Cancer [eCQM]
• Measure #483 – Person-Centered Primary Care Measure Patient Reported Outcome Performance Measure (PCPCM PRO-PM) [MIPS CQM]
• Measure #487 – Screening for Social Drivers of Health [MIPS CQM]
• Measure #488 – Kidney Health Evaluation [MIPS CQM, eCQM]
• Measure #490 – Appropriate Intervention of Immune-Related Diarrhea and/or Colitis in Patients Treated with Immune Checkpoint Inhibitors [MIPS CQM]
• Measure #493 – Adult Immunization Status [MIPS CQM]
• Measure #497 – Preventive Care and Wellness (Composite) [MIPS CQM]
• Measure #498 – Connection to Community Service Provider [MIPS CQM]
• Measure #503 – Gains in Patient Activation Measure (PAM) Scores at 12 Months [MIPS CQM]

Specifications for MIPS measures not supported through the AQUA registry are available in the CMS QPP Resource Library.

Automatically Calculated Measures

CMS will automatically calculate four administrative claims measures for individuals, groups, and virtual groups, assuming the case minimums and clinician requirements are met. Participants do not need to do any work for these measures; it is all done by CMS. The two that are relevant for urologists are:

• Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-based Incentive Payment System (MIPS) Eligible Groups (available for groups and virtual groups only)
• Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

Scoring the Quality Category

MIPS participants earn points for the Quality category based on how their results compare to that of other participants. As detailed below, measure results are compared to benchmarks based on historical data to determine the number of achievable points for submitted measures. Next, bonus points are awarded as applicable, and a percentage score is computed. Then, the final score for the Quality performance category is calculated by weighting the Quality percentage score by the Quality weight (for 2024, this is 30 percent for individuals, groups, and virtual groups).

Quality Benchmarks

A series of historical benchmarks has been established for each measure, for each reporting mechanism (e.g., if a measure can be reported as a CQM and an eCQM, it will have two benchmarks). For 2024, those benchmarks were calculated using data reported for 2022. CMS created a matrix where each measure’s results have been divided into deciles, ranging from 1 to 10.

• Typically, measures can earn between 1 and 10 achievement points if they can be scored against a benchmark.
• Participants can use this matrix to determine into which decile his/her performance falls, then use this information to determine the score for that particular measure.

Topped Out Measures

If a measure is considered “topped out” by CMS, this means most participants who have reported the measure have scored very well on it. CMS has begun phasing out many of the topped out measures and is trying to discourage participants from using remaining topped out measures by awarding lower point values. For some topped out measures, CMS does not award the full 10 points, even if measure results are perfect.

Measures Without Historical Benchmarks

If a measure does not have a historical benchmark, CMS will attempt to calculate one using 2024 data. If no historical benchmark exists and one cannot be calculated using 2024 data, CMS will not award any points for that measure. Small practices will continue to earn 3 points for reporting on measures without a benchmark.

New Measures

For a new measure in its first performance year, a minimum of 7 points will be awarded for those who successfully report on such a measure. During its second performance year, the measure will have a 5-point floor.

The benchmark values for MIPS and QCDR measures are available in a zipped folder located on the CMS QPP Website. Note that the benchmark values are subject to change during the year, so clinicians should check the QPP website periodically to see if a revised version of the benchmark file has been released.

Quality Bonus Points and Improvement Scoring

Six bonus points will be awarded to small practices who submit data for at least one quality measure. A practice must have 15 or fewer clinicians to be considered small.

MIPS participants may be able to earn as many as 10 additional percentage points if their score for the Quality category improved compared to their score in the previous year. The bonus is awarded using the formula:  10 x (increase in achievement percent score from prior performance year / prior performance year achievement percent score).

Calculating the Final Score for the Quality Performance Category

To calculate a provider’s Quality category score:

• One must use the benchmark information for each measure to determine the number of achievable points for that measure.
• Those points are added together, along with any bonus points that have been earned.
• That total is divided by total number of achievable measure points (in most cases, this is 60 points).
• If an improvement percent score has been earned, it is then added to this value to determine the final score.
• The score is displayed as a percentage, but a maximum score cannot exceed 100 percent.

If a participant scores perfectly on all 6 measures and achieves 10 points for each, that participant would receive a Quality percentage score of 100 percent (60/60 * 100%). However, most participants will not have perfect scores on each submitted measure.

Example

• A participant has the following scores for six measures: 3, 8, 6, 4, 5, and 9, for a total of 35 points, along with 6 bonus points because the participant is a solo practitioner.
  • The total number of points would be 41, which is then then divided by 60 (this equals 68 percent).
  • But this participant is also awarded an improvement percent score of 2 percent. Thus, that participant’s percentage score for the Quality category is 70 percent.
• The formula for determining the total points for the Quality category is: (quality performance category percent score) x (quality category weight) x 100
• The final Quality performance category score would be 70 percent x 30 percent x 100 =21 points.

Note that the Quality category weight might change for some participants. For example, if a non-small practice is given an exception for the Promoting Interoperability performance category, the Quality category weight becomes 55 percent in 2024 (30 percent + 25 percent).

Performance Category: Cost

 

(Source: U.S. Centers for Medicare & Medicaid Services)

There are 29 cost measures available for 2024 (two that are population-based and 27 that are episode-based). For individuals, groups, and virtual groups, the weight for the Cost performance category accounts for 30% of the total MIPS score. The measures included in the Cost performance category assess:

• The overall cost of care provided to Medicare patients, with a focus on the primary care they received;
• The cost of services provided to Medicare patients related to a hospital stay; and
• Costs for items and services provided during specific episodes of care for Medicare patients.

MIPS participants do not have to submit performance data to CMS for the Cost category. Instead, CMS uses Part A and B Medicare claims data (and, sometimes, Part D claims) to calculate participants’ Cost category score.

The two population-based cost measures include:

• Total Per Capita Cost (TPCC) – This measure assesses Medicare Part A and Part B costs during the year for attributed patients. Attribution of a given patient is based upon which clinician or group, respectively, bills allowed charges for primary care services delivered to that patient (determined by select E&M CPT/HCPCS codes). This measure is payment-standardized, risk-adjusted, and specialty-adjusted. There is a 20-case minimum for this measure. Urologists should not be attributed primary care patients; however, the AUA still recommends that providers review their annual reports to ensure that this has not happened.
• Medicare Spending per Beneficiary (MSPB) Clinician Measure – The MSPB Clinician measure assesses the cost to Medicare of services provided to a patient during an MSPB Clinician episode (i.e., the period immediately before, during, and after a patient’s hospital stay). An MSPB episode includes most Medicare Part A and Part B claims during the episode, specifically claims with a start date between three days before a hospital admission (the “index admission” for the episode) through 30 days after hospital discharge. The measure excludes certain services that are unlikely to be influenced by the clinician’s care decisions. Inpatient medical episodes are attributed separately from inpatient surgical episodes. The case minimum for this measure is 35 episodes.

The 27 episode-based cost measures differ from the population-based cost measures in that they include only items and services that are related to the episode of care for a specific clinical condition or procedure, as opposed to all Medicare part A and B services over a specific timeframe. The length of the episode varies, depending on the measure. Three types of episode-based cost measures have been developed:

• Procedural:  These measures focus on procedures of a defined purpose or type. They assess the cost of care that’s clinically related to a specific procedure provided during an episode’s timeframe. The case minimum for these measures is 10 episodes (except the Colon and Rectal Resection measure, which has a case minimum of 20 episodes).
• Acute inpatient medical condition:  These measures represent treatment for a self-limited acute illness or treatment for a flare-up or exacerbation of a condition requiring a hospital stay. They assess the cost of care clinically related to specific acute inpatient medical conditions provided during an episode’s timeframe. The case minimum for these measures is 20 episodes.
• Chronic condition:  These measures assess costs for ongoing management of a long-term health condition. They assess the cost of care clinically related to the care and management of patients’ specific chronic conditions provided during a total attribution window divided into episodes. The case minimum for these measures is 20 episodes.

The Renal or Ureteral Stone Surgical Treatment measure is a risk-adjusted, procedural cost measure applicable to many urologists. As a procedure measure, the case minimum is 10 episodes. The episode window for this measure spans from 90 days prior to the procedure to 30 days after.

Calculating the Final Score for the Cost Performance Category

For the Cost performance category, CMS will compare participants’ performance to that of other MIPS-eligible clinicians and groups during the performance period. More specifically, to calculate the score for each measure, CMS will determine the ratio of standardized observed episode costs to the expected costs and multiply that value by the average episode cost (benchmark).

For each scored measure, CMS will then assign 1-10 achievement points, based on the decile in which the score falls. The Cost performance category percent score is calculated as the total number of achievement points earned divided by the number of possible achievement points (i.e., the total number of scored measures times 10). Note that not all clinicians will qualify for all cost measures, and some may not qualify for any.  In addition, there is a maximum cost improvement score of 1 percentage point available for the Cost performance category.

Example

• A participant is scored on two cost measures (receiving 7 points for one and 9 points for the other).
  • The total number of points would be 16, which is then then divided by 20 (this equals 80 percent).
  • However, this participant did not receive an improvement point.
• The formula for determining the total points for the Quality category is: (cost performance category percent score) x (cost category weight) x 100
• The final Cost performance category score would be 80 percent x 30 percent x 100 =24 points.

Performance Category: Promoting Interoperability

 

(Source: U.S. Centers for Medicare & Medicaid Services)

The goal of the Promoting Interoperability (PI) performance category is to foster the electronic exchange of health information using certified electronic health record technology (CEHRT). Use of technology to exchange and make use of information (i.e., interoperability):

• Reduces burden associated with communicating patient information and, by extension,
• Improves patient access to their health information,
• Improves information exchange between clinicians and pharmacies, and
• Improves the systematic collection, analysis, and interpretation of healthcare data.

For 2024, the weight for the PI performance category for individuals, groups, and virtual groups is 25 percent (that is, this category accounts for 25% of the total MIPS score).

The PI category focuses on 4 objectives:

• e-Prescribing
• Health Information Exchange
• Provider-to-Patient Exchange
• Public Health and Clinical Data Exchange

Participants can report either directly or through a third party, such as the AQUA registry.  Additionally, all participants must use an Electronic Health Record (EHR) that meets the ONC certification criteria specified in 45 CFR 170.315 of the Code of Federal Regulations.  Note that previously, participants were required to be certified to meet the 2015 Edition Cures Update certification criteria.  However, to align with current and future regulation by the Office of the National Coordinator for Health Information Technology (ONC), CMS no longer uses this wording to describe the certification criteria. 

Exemptions and Exceptions

• Some participants may be automatically exempted from this performance category:
  • Clinical social workers
  • A special status such being ambulatory surgical center (ASC)-based, hospital-based, non-patient facing, or a small practice
• Others may qualify for a hardship exception if they:
  • Use decertified EHR technology,
  • Have insufficient internet connectivity,
  • Lack control over CEHRT availability, or
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues.

The hardship exception results in the re-weighting of the PI category to zero. If any data are submitted for the PI category, the reweighting will be canceled, and the data will be scored.

Those who are not automatically exempted must apply for the exception by December 31, 2024. Even if a participant received an exception previously, they must apply again in 2024.

PI Measures

For the PI performance category, participants must report on either 6 or 7 required measures. Data for these measures must be collected during the same continuous 180-day period (or more) during the calendar year (note that this is a change from 2023, where the required performance period was only 90 days).

In addition to the PI measures, participants must provide their EHR’s CMS Identification code from the Certified Health IT Product list and complete the required attestations.  

Information about the PI measures is shown below.

Objective	Measures	Available Points (based on performance)
e-Prescribing	e-Prescribing	1-10 points
	Query of Prescription Drug Monitoring Program (PDMP)	10 points
Health Information Exchange	Option 1: Support Electronic Referral Loops by Sending Health Information and Support Electronic Referral Loops by Receiving and Reconciling Health Information	1-15 points 1-15 points
	Option 2: HIE Bi-Directional Exchange	30 points
	Option 3: Enabling Exchange under TEFCA	30 points
Provider to Patient Exchange	Provide Patients Electronic Access to Their Health Information	1-25 points
Public Health and Clinical Data Exchange	Report on the following measures: Immunization Registry Reporting (required) Electronic Case Reporting (required)	25 points for the objective
	Option to report at least one of the following public health agency or clinical data registry measures: Public Health Registry Reporting (optional) Clinical Data Registry Reporting (optional) Syndromic Surveillance Reporting (optional)	5 bonus points

The specifications for the measures are posted on the CMS QPP Website.

Note that the work required for all PIs must begin no later than July 5, 2024 (in order to have a full 180-day performance window). As with the Improvement Activities performance category, documentation supporting PI reporting is not required at the time of attestation. However, documentation should be compiled, and would be required in the event of a CMS audit. Participants must keep this documentation for six years after attestation. Requirements for this documentation can be located in the CMS QPP Resource Library.

Calculating the Final Score for the Promoting Interoperability Performance Category

Participants can earn a total of 100 points based the results of the required measures.

• The total score can include 5 bonus points received for submitting a “yes” response for one of the optional Public Health and Clinical Data Exchange measures:
  • Public Health Registry Reporting
  • Clinical Data Registry Reporting
  • Syndromic Surveillance Reporting.
• A score of zero points will be earned for the PI performance category unless:
  • A participant reports either a numerator of at least ‘1’ or a ‘yes’ for required measures, assuming an exclusion is not claimed
  • Data are collected in CEHRT with functionality that meets ONC requirements for at least 180 continuous days in 2024
  • A “yes” is submitted to the Actions to Limit or Restrict Interoperability of CEHRT Attestation (formerly named Prevention of Information Blocking)
  • A “yes” is submitted to the SAFER Guides attestation measure
  • A “yes” or “no” is submitted to the ONC Direct Review Attestation
  • A “yes” is submitted to show that a participant has completed the Security Risk Analysis measure in 2024
  • The level of active engagement for the Public Health and Clinical Data Exchange measures being reported is submitted
  • The EHR's CMS identification code from the Certified Health IT product List (CHPL) is reported.
• Claiming an allowed measure exclusion causes that measure’s points to be shifted to a different measure.

Points for each measure are earned depending on the type of measure. Measures with a numerator and denominator receive points based on their results, which are multiplied by the maximum number of points available for the measure.

Example

• If a participant has a 75% performance for the Provide Patients Electronic Access to Their Health Information measure (which is worth a maximum of 25 points), they would earn 19 points (0.75*25) towards the PI performance category.

• Attestation measures where the participant responds “yes” receive the maximum number of points available for the measure.

• To calculate the final percent score for the PI performance category, sum the points earned for each measure and divide by 100.

• Note that the score is capped at 100 percent.

• The formula to determine the total points for the PI category is: (PI performance category percent score) x (PI category weight) x 100.
• If the final percent score for the PI category is 92 percent, the final PI score would be: 92 percent x 25 percent x 100 =23 points.

Performance Category: Improvement Activities

(Source: U.S. Centers for Medicare & Medicaid Services)

The Improvement Activities (IA) performance category measures participation in activities that improve clinical practice, care delivery, and outcomes. Participants can select from over 100 activities that pertain to patient engagement, care coordination, patient safety, and other relevant areas. In 2024, the weight for the IA performance category is 15 percent for individuals, groups, and virtual groups (that is, this category accounts for 15 percent of the total MIPS score).

IAs must be implemented for at least one continuous 90-day performance period (during 2024) unless otherwise stated in the activity description. They can be reported by individuals or through group reporting. If a practice is using group reporting, at least 50 percent of the members of the practice must implement the same IA in order to earn credit, although they do not have to implement it at the same time.

Each IA typically is given a medium weight (10 points) or a high weight (20 points). The maximum number of points available for this performance category is 40. However, some groups (e.g., small practices, rural practices, those in health professional shortage areas, and non-patient facing practices) earn 20 points for medium-weighted activities and 40 points for high-weighted activities. Those working in a recognized or certified patient-centered medical home or comparable specialty practice can receive the full 40 points for this category. All IAs must begin no later than October 3, 2024 (to have a full 90-day performance window).

Participants will attest to their improvement activities (note that this can be done directly or through a third party, such as the AQUA registry). Documentation supporting improvement activities is not required at the time of attestation. However, documentation should be compiled, and would be required in the event of a CMS audit. Participants must keep this documentation for six years after attestation. CMS has published requirements for this documentation. The AUA recommends that participants document as much information as possible about the activities you complete.

Example

• If administering a patient satisfaction survey for 90 days, note in the patient charts who received one and when.
• If attending an Institute for Healthcare Improvement event, save proof of registration and any materials (slides, handouts, etc.) that may have been distributed for the event.

Getting Started

Prior to selecting IAs, practices should analyze their practices to identify:

• What areas of the practice are in need of improvement
• What changes would help to improve the patient experience
• What existing improvement activities could satisfy the IA performance category

Hopefully, if you need to start new activities, or amend existing ones, you can implement something that will not require a significant outlay of time, staffing or other resources (assuming it would still positively impact patient care, experience, or outcomes). For example, programs may be offered through your local hospital system or through an insurance program that could satisfy an IA requirement.

Selecting IAs

There are more than 100 IAs available for reporting. They are organized into eight categories, as follows:

• Achieving Health Equity (AHE)
• Behavioral and Mental Health (BMH)
• Beneficiary Engagement (BE)
• Care Coordination (CC)
• Emergency Response and Preparedness (ERP)
• Expanded Practice Access (EPA)
• Patient Safety and Practice Assessment (PSPA)
• Population Management (PM)

The AUA reviewed the 106 IAs identified by CMS for 2024.

• Activities highlighted in blue are those that the AUA believes urologists should be able to easily implement or adapt for their practices.
• Activities highlighted in green can be completed through participation in the AUA Quality (AQUA) Registry, a Qualified Clinical Data Registry (QCDR).
  • Send an email to AQUA@AUAnet.org, or call 855-898-AQUA (2782) if you are interested in joining the AQUA Registry.

When considering IAs:

• You should review the full list of activities to see if there are others that may be more applicable to your practice. 
• Carefully review the CMS documentation requirements to ensure you understand and can meet them.
  • If you choose to participate in MIPS via a QCDR, you must select and attest each improvement activity separately. Reporting for some quality measures may also fulfill IA reporting requirements.
  • You will not receive credit for multiple IAs by selecting one activity that includes participation in a QCDR.

Participants must engage in IAs for at least 90 consecutive days. Sometimes the work you do will satisfy multiple IAs, so consider taking advantage of this overlap.

Improvement Activity Resources

Below, we have provided brief overviews and links for some of the available IAs.  However, you should refer to CMS’s IA documentation resources for the full inventory of IAs and their associated descriptions, objectives, and documentation criteria. 

• IA_EPA_3 – Collection and use of patient experience and satisfaction data on access – This activity focuses on collecting feedback from your patients and then using this information to implement change in your practice. Many organizations offer patient satisfaction surveys. Practices can also design their own surveys focusing on questions they find more useful. CMS requires some degree of patient stratification such as race/ethnicity, disability status (if available), sexual orientation (if available), sex, gender identity (if available), and geography. After accumulating data for 90 days, the next step is reviewing it and determining how to take advantage of the information gathered. If all of your surveys are noting the same thing, it is either something you are doing very well or something that should be changed. Look for small steps that can make a big difference but will not greatly impact other resources.
• IA_PM_16 – Implementation of medication management practice improvements – While there are several ways to satisfy this activity, the AUA recommends that urologists do so through medication reviews or reconciliation. CMS recommends that participants implement the “AHRQ Create a Safe Medicine List Together” strategy.
• IA_CC_1 – Implementation of use of specialist reports back to referring clinicians or groups to close referral loop – There are two ways to satisfy this activity, and both involve documenting reports in the patient’s file. If you are referring patients to other providers, note that in the patient’s chart and make sure to document any reports or results the other provider sends you. Likewise, if patients are referred to you, note that in the chart and make sure to document that you provided reports and/or results to the referring provider. This activity may also satisfy IA_CC_12.
• IA_CC_2 – Implementation of improvements that contribute to more timely communication of test results – This activity requires that you contact any patient that has an abnormal test result and that you document the result and how and when you contacted the patient, which could be by mail, phone call, etc. CMS does not define “timely,” but most offices already have a working definition of this. The strategies used to improve timeliness must be documented by the eligible clinician.
• IA_CC_7 – Regular training in care coordination – A practice must have documentation of participation in/implementation of regular care coordination Many organizations that offer care coordination resources, such as the Agency for Healthcare Quality and Research’s webinar series entitled TeamSTEPPS. The webinars also are archived so they can be viewed whenever it is most convenient. Whatever program you decide to use, keep validation of registration/participation in the event. Your practice (or at least a quality improvement team) should discuss the content of the webinars and implement what is feasible. CMS stresses that the main goal of this activity is to meet patients’ needs. Thus, there should be some mechanism for gathering this information. CME and other forms of accreditation often are offered for these webinars and training sessions.
• IA_CC_12 – Care coordination agreements that promote improvements in patient tracking across settings - If you are referring patients to other providers, note that in the patient’s chart (either paper or electronic) and make sure to document any reports or results the other provider sends to you. Likewise, if patients are referred to you, note that in the chart and make sure to document that you sent reports and/or results to the referring provider. This activity may also satisfy IA_CC_1 and IA_CC_13.
• IA_BE_6 – Regularly assess patient experience of care and follow up on findings – If you are using a patient survey administered by a third party survey administrator/vendor (as discussed in IA_EPA_3), you can satisfy this activity by taking it to the next level. For example, your practice could follow up with patients to address any concerns they might have and use this information to design and implement an improvement plan.
• IA_BE_15 – Engagement of patients, family, and caregivers in developing a plan of care – To complete this activity you could utilize an advanced care plan or a plan specific to the urological treatment you are providing. While you probably do not need all the information that would be noted in an advanced care plan, it is good information to have in the patient’s file. Many patients already have such plans; so, it is merely a matter of obtaining it and putting a copy in the file. In order to satisfy this activity, you must produce a report from your electronic health record showing the plan of care and engagement/inclusion of the patient, family, and/or caregivers. Doing this activity also may satisfy IA_PM_13 and IA_CC_9.
• IA_PSPA_3 – Participate in Institute for Healthcare Improvement (IHI) training/forum event; National Academy of Medicine, AHRQ Team STEPPS or other similar activity – Many national organizations, including the AUA, offer seminars and events focused on quality improvement and patient safety, and participating in one (either in-person or online, and some free of charge) would satisfy this activity. The AUA offers the Quality Improvement Summit. Check the websites of other organizations (such as ihi.org, nam.edu, or ahrq.gov/teamstepps) for their offerings throughout the year.
• IA_PSPA_4 – Administration of the AHRQ Survey of Patient Safety Culture – Employees of the practice would need to complete this survey and results must be submitted to AHRQ. AHRQ provides a user’s guide, as well as the form, to help with its administration. At this point, CMS does not require any analysis of the results or follow-up on the survey. So, simply completing and submitting would be an inexpensive and quick way to complete an activity. This activity can only be done once every four years.
• IA_PSPA_8 – Use of patient safety tools – Surgical risk calculators [such as the one available through the American College of Surgeons (ACS)], the International Prostate Symptom Score (IPSS), or AUA Symptom Index (AUA-SI) are widely used patient safety tools in urology. If you already use one of these or plan to start, document this act in a patient’s chart when appropriate in order to satisfy this activity. The ACS surgical risk calculator is also available on the AUA Guidelines app. The AUA document series on Optimizing Outcomes in Urologic Surgery also highlights a variety of tools such as ERAS protocols, nutrition assessment tools, etc. Quality measure #476 also pertains to the IPSS and AUA-SI.
• IA_PSPA_9 – Completion of the AMA STEPS Forward program – The STEPS Forward program is an online initiative geared at improving practice efficiency as well as improving care and the patient experience. This tool can be used at your convenience and allows you to customize your educational experience by focusing on both clinical and practical modules. Participants may obtain a certificate of completion for at least one AMA STEPS Forward module or have documentation that they have implemented what they learned into their processes of care. CME is available for some modules. Start by watching the overview video.

Many activities may be achieved through QCDR participation. The AUA offers the AQUA Registry, which is a CMS-approved QCDR. AQUA can also be used to complete the Quality reporting program and satisfy some aspects of Promoting Interoperability. To learn more about AQUA, send an email to AQUA@AUAnet.org or call 855-898-AQUA (2782).

Disclaimers:

• The AUA encourages practices to download and review CMS’s IA data validation requirements.
• Providers must maintain documentation supporting the completion of each activity in the event of a future CMS audit.
• The AUA and AQUA Registry cannot guarantee a positive/negative payment adjustment.

Calculating the Final Score for the Improvement Activities Performance Category

As noted earlier, each IA is worth either 10 points or 20 points (although the point values may be higher for some participants), and the maximum number of points possible for the IA category is 40. Participants can select whatever combination of activities they desire to reach those 40 points. Again, they must engage in those activities for at least 90 continuous days, unless otherwise stated in the activity description. The IA performance category accounts for 15 percent of the overall MIPS score for individuals, groups, and virtual groups.

Example

• A participant implements 2 medium-weight activities and one high-weight activity.
  • Their IA performance category percent score would be (10+10+20)/40=100 percent.
  • Note that a participant cannot earn more than 100% for this performance category (even if they attest to implementing additional improvement activities).

• The formula for determining the total points for the Improvement Activities category is: (IA performance category percent score) x (IA category weight) x 100.

• The final Improvement Activities performance category score would be 100 percent x 15 percent x 100 =15 points.

Calculating the Final MIPS Score

(Source: U.S. Centers for Medicare & Medicaid Services)

The final MIPS score is calculated by adding together the final scores for each of the four performance categories, along with any “complex patient” bonus points earned.

Complex Patient Bonus

• CMS recognizes the challenges and costs incurred by clinicians for caring for complex patients and thus will analyze participant data to determine the number of bonus points (if any) for complex patients.
• Up to 10 bonus points will be awarded, depending on the level of clinical complexity and social risk.
  • Each provider will be evaluated individually to determine their eligibility to receive the bonus.
• The bonus is based upon Hierarchical Condition Category (HCC) risk scores that incorporate age, gender, diagnoses from the previous and whether they’re eligible for Medicaid, first qualified for Medicare because of disability, or live in an institution (to determine medical complexity) and the proportion of patients with dual Medicare-Medicaid eligibility (as a proxy for social risk).

Example

• The performance category scores were:
  • Quality: 21 points
  • Cost:  24 points
  • Improvement Activities: 15 points
  • Promoting Interoperability:  23 points
• Assume this participant also earned two complex patient bonus points.   
• This participant’s final MIPS score would be: 21+24+15+23+2 = 85 points.

Additional Information

CMS has developed extensive descriptions for, and detailed documentation of, the requirements and operation of the MIPS program. These are available on its QPP website. A few of the most helpful resources available through this site’s Resource Library, include:

2024 MIPS Quick Start Guide
2024 MIPS Eligibility and Participation Quick Start Guide
2024 Quality Quick Start Guide
2024 Quality Benchmarks
2024 Cost Quick Start Guide
2024 MIPS Summary of Cost Measures
2024 MIPS Cost Measure Codes Lists
2024 Improvement Activities Quick Start Guide
2024 Improvement Activities Inventory
2024 Promoting Interoperability Quick Start Guide
2024 Promoting Interoperability Measure Specifications

Note that CMS may add additional documents to this resource library or update the documents throughout the year.

Finally, other sources of information regarding MIPS include the following: 

CMS Quality Payment Program Help Desk

Phone: 866-288-8292
E-mail: QPP@cms.hhs.gov

AUA Quality & Measurement Department

E-mail: quality@auanet.org

AQUA Registry Help Desk

E-mail: AQUA@AUAnet.org