Final Day for 90-Day Improvement Activities

The Merit-based Incentive Payment System (MIPS) is a critical program for healthcare providers, especially those participating in Medicare. To stay compliant and optimize your performance, it’s essential to be aware of the important upcoming MIPS dates and deadlines for 2024 and beyond. Missing a key deadline could result in reduced Medicare reimbursements or missed opportunities for incentives.

Here’s a breakdown of the crucial dates clinicians should mark on their calendars:

October 3, 2024: Final Day for 90-Day Improvement Activities

If you’re participating in MIPS for the 2024 performance period and haven’t yet started collecting data for the Improvement Activities performance category, you must do so by

October 3, 2024. This is the last day to begin a continuous 90-day performance period. Improvement activities typically require at least 90 days of data collection, though some activities may require a year-long or alternate performance period. Be sure to check the description of the activity you’re completing to confirm the duration required.

October 11, 2024: Last Call for Targeted Reviews and Special Requests

This date marks the final opportunity to request a MIPS targeted review for your 2023 performance year feedback, including your final score and payment adjustment factors. If you believe there’s an error in your performance feedback, you have until 8 p.m. ET on October 11 to submit a review request.

Additionally, October 11 is the last day to submit requests for MIPS Extreme and Uncontrollable Circumstances (EUC) performance category reweighting due to the Change Healthcare Cyberattack for the 2023 performance year. If your practice was affected, this is your chance to request reweighting to avoid penalties based on those extraordinary circumstances.

October 2024: MIPS Eligibility Updates

During October, the Centers for Medicare & Medicaid Services (CMS) will update MIPS eligibility for the 2024 performance year, based on the June 30 Alternative Payment Model (APM) snapshot. This update will determine whether you’re required to participate in MIPS and what category weights apply to you, depending on your participation in an APM.

You can check your MIPS APM participation status and your Qualifying APM Participant (QP) determinations using the QPP Participation Status Tool.

December 2, 2024: MVP Registration Deadline

If you plan to report through a MIPS Value Pathway (MVP) for the 2024 performance year, you need to register by December 2, 2024. The MVP program offers a streamlined reporting framework tailored to specific medical specialties and practice types, making it easier to meet MIPS requirements. Ensure you complete your registration by this deadline to take advantage of this option.

December 2024: Eligibility Finalization and 2025 Preview

As we approach the end of 2024, more MIPS updates will be released. In December, CMS will finalize MIPS eligibility for the 2024 performance year using August 31 APM snapshot data. This will give a clearer picture of which clinicians are required to participate and under what conditions.

In addition, initial eligibility for the 2025 performance year will be released in December. Clinicians and groups can use this information to plan ahead for the next performance period.

December 31, 2024: Year-End Deadlines

The last day of 2024 is critical for several reasons. First, it’s the final day of the 2024 MIPS performance year, meaning it’s the last opportunity to collect data that can be submitted for performance evaluation.

Additionally, December 31 marks the closing of the 2025 performance year virtual group election period at 11:59 p.m. ET. After this time, clinicians can no longer submit, revise, or retract their election to participate as part of a virtual group for 2025.

Finally, the QPP Exception Application window also closes at 8 p.m. ET on December 31. This applies to clinicians seeking an Extreme and Uncontrollable Circumstances (EUC) Exception or a Promoting Interoperability Hardship Exception for the 2024 performance year.

January 1, 2025: Payment Adjustments Take Effect

Beginning on January 1, 2025, MIPS payment adjustments will go into effect based on your 2023 performance. These adjustments could increase or decrease your Medicare reimbursements, depending on your final score. Clinicians who performed well in 2023 can expect positive adjustments, while those who didn’t meet the benchmarks may see a reduction in their payments.

January 2, 2025: Data Submission Period Opens

Clinicians should be prepared to begin submitting their 2024 performance year data starting on January 2, 2025. Submitting early will allow ample time to review and correct any discrepancies, ensuring accurate data for performance evaluation.

Key Takeaways

MIPS participation involves several crucial deadlines, and missing them can have financial repercussions. Clinicians should take note of the following key actions: