CMS 2024 Quality Payment Program Update for Clinical Social Workers
On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released updates to the Quality Payment Program (QPP) which can be found in the 2024 Physician Fee Schedule (PFS) and the QPP Resource Library. The QPP was established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Its purpose is to provide tools and resources to help providers give their patients the highest-value of care. As eligible clinicians, clinical social workers (CSWs) report on measures and may receive a positive payment adjustment up to 9 percent when reporting quality measures correctly. However, clinicians may be penalized with a negative payment adjustment up to 9 percent if measures are reported incorrectly. This document provides updates specific to clinical social workers who are eligible to participate in the Quality Payment Program.
Eligibility
CSWs participate in the QPP through the Merit-based Incentive Payment System (MIPS).There are different ways to become an MIPS eligible clinician. To be eligible for MIPS, CSWs must exceed the annual low-volume threshold as an individual or group by meeting the following criteria:
- Billing over $90,000 for Medicare Part B services
- Providing over 200 covered services to Medicare Part B patients
- Seeing more than 200 Medicare Part B patients
Clinicians who exceed all three elements of a low-volume threshold must participate and report in MIPS.Those who exceed one or two elements of the low volume threshold are not required to participate nor report in MIPS.
For more information, CSWs can refer to the 2024 MIPS Eligibility page or use the QPP Participation Status Tool to verify their eligibility status.
Updates on Traditional MIPS Measures
CSWs have the option to satisfy MIPS reporting requirements through traditional MIPS. MIPS eligible clinicians submit quality measures. There are currently 16 approved quality measures for CSWs. CMS has also approved five new measures for the year 2024 and will be removing two measures from the CSW skillset. The changes are as follows:
Current Measures
- Adherence to Antipsychotic Medications for Individuals with Schizophrenia
- Advance Care Plan
- Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment
- Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
- Dementia: Cognitive Assessment
- Dementia: Education and Support of Caregivers for Patients with Dementia
- Dementia: Functional Status Assessment
- Dementia: Safety Concern Screening and Follow-Up for Patients with Dementia
- Depression Remission at Twelve Months
- Documentation of Current Medications in the Medical Record
- Elder Maltreatment Screen and Follow-Up Plan
- Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling
- Screening for Social Drivers of Health
- Tobacco Use and Help with Quitting Among Adolescents
Additional measures for 2024
- Initiation and Engagement of Substance Use Disorder Treatment
- Connection to Community Service Provider
- Improvement or Maintenance of Functioning for Individuals with a Mental and/or Substance Use Disorder
- Initiation, Review, and/or Update to Suicide Safety Plan for Individuals with Suicidal Thoughts, Behavior, Or Suicide Risk
- Reduction in Suicidal Ideation or Behavior Symptoms
Measures to be removed from the CSW skillset in 2024:
- Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
- Tobacco Use and Help with Quitting Among Adolescents
Updates on MVPs
CMS continues to develop their MIPS Value Pathways (MVPs. CSWs and other healthcare professionals have the option to report on MVPs that are specific to their specialty practice or condition and selected from a set of CMS approved quality measures and activities. MVPs are a voluntary way to meet MIPS reporting requirements. Each MVP includes a subset of measures and activities that are related to a specialty or medical condition to offer more meaningful participation in MIPS.
CMS has finalized five new MVPs and made modifications to existing ones totaling to 16 MVPs for the 2024 performance period.MVP measures most relevant to clinical social work practice can be found in the 2024 QPP Final Rule MVP Guide on page 14 Table A.4 of the Quality Care in Mental Health and Substance Use Disorders MVP. The updates are as follows:
New MVP Measures
Cost
- Depression
- Psychoses and Related Conditions
CMS will calculate performance cost measures included in the MVP using administrative claims data
Quality
- Q502: Improvement or Maintenance of Functioning for Individuals with a Mental and/or Substance Use Disorder
- Q504: Initiation, Review, and/or Update to Suicide Safety Plan for Individuals with Suicidal Thoughts, Behavior, Or Suicide Risk
- Q505: Reduction in Suicidal Ideation or Behavior Symptoms
Improvement Activities
- IA_BMH_14: Behavioral/Mental Health and Substance Use Screening & Referral for Pregnant and Postpartum Women
- IA_BMH_15: Behavioral/Mental Health and Substance Use Screening & Referral for Older Adults
- IA_MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
Revised MVP Measures
Quality
- Q134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Q366: Follow-Up Care for Children Prescribed ADHD Medication (ADD)
- Q370: Depression Remission at Twelve Months
- Q382: Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment
- Q383: Adherence to Antipsychotic Medications for Individuals with Schizophrenia
- Q487: Screening for Social Drivers of Health
- Q479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Systems (MIPS) Eligible Clinician Groups
- Q484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
Population Health Measures
Participants must select one population health measure at the time of MVP registration. CMS will then calculate these measures through administrative claims to be scored as part of the quality performance category.
NASW commends CMS’ efforts to improve MVPs to better meet the needs of clinicians and the patients they serve. The association also appreciates CMS’ efforts to add to the CSW specialty skill set and agrees with the proposed measure.
How to Register
CSWs can visit the QPP website to find more information on Timeline and Important Deadlines along with information on the registration process.
Due to the complexities of reporting and to avoid a negative penalty adjustment, NASW strongly recommends using a mental health registry for the reporting of measures. A registry is a vendor that collects data from an eligible MIPS individual clinician or group and submits the data to Medicare on their behalf.There is a fee associated with the use of a registry. Registries that report mental health and substance use disorder quality measures include, but are not limited to, the following:
For Help and Additional Information
CSWs are encouraged to contact the QPP Service Center at 1-866-288-8292, Monday through Friday, 8 am to 8 pm ET or by email at QPP@cms.hhs.gov. Those who have questions are also encouraged to review the 2024 Final Rule FAQs for the QPP. Assistance is also available from NASW by emailing Denise Johnson, LCSW-C, Senior Practice Associate, at djohnson.nasw@socialworkers.org.