In November the Centers for Medicare & Medicaid Services published the 2024 Quality Payment Program final rule, seeking to further advance Medicare’s overall value-based care strategy of growth, alignment, and equity. An AASM analysis of the rule, including key highlights specific to sleep medicine, is provided below. An analysis of the 2024 physician fee schedule with updated payment and RVU documents will be posted separately.

Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs)

  • 16 total MVPs
    • New:
      • Focusing on Women’s Health
      • Quality Care for the Treatment of Ear, Nose, and Throat Disorders*
      • Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
      • Quality Care in Mental Health and Substance Use Disorders
      • Rehabilitative Support for Musculoskeletal Care
    • Modified:
      • Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
      • Advancing Cancer Care
      • Advancing Care for Heart Disease
      • Advancing Rheumatology Patient Care
      • Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
      • Improving Care for Lower Extremity Joint Repair
      • Optimal Care for Kidney Health
      • Optimal Care for Patients with Episodic Neurological Conditions
      • Patient Safety and Support of Positive Experiences with Anesthesia
      • Value in Primary Care
      • Supportive Care for Neurodegenerative Conditions

*The AASM was successful in advocating for the inclusion of the Sleep Apnea: Severity Assessment at Initial Diagnosis measure in the Treatment of Ear, Nose, and Throat Disorders MVP, along with the inclusion of all other proposed quality measures and improvement activities in this MVP.

Promoting Interoperability Performance Category

CMS increased the performance period from a minimum of 90 days to a minimum of 180 days to promote continuity across CMS and align with the Medicare Promoting Interoperability Program.

MIPS Payment Adjustments

The performance threshold will remain at 75 points for the 2024 performance period instead of the proposed 82 points.

Data Completeness

There will not be an increase to the 75% data completeness threshold for the 2027 performance period, as proposed.

Targeted Review

The targeted review period will continue to be approximately 60 days; clinicians, groups, virtual groups, and APM entities may request a review 30 days before payment adjustments are released up to 30 days after they are released.

Advanced Alternative Payment Models (APMs)

CMS finalized several policies for Advanced APMs:

  • Removed the 75% numerical threshold and required the use of certified EHR technology (CEHRT) with a one-year delay to the 2025 performance year
  • Did not finalize making qualifying APM participants (QPs) determinations at the individual eligible clinician level only, instead of the APM entity level, as proposed
  • Under current statute, the QP threshold percentages will increase beginning with the 2024 performance year.
    • Medicare payments:
      • QP threshold increasing from 50% to 75%
      • Partial QP threshold increasing from 40% to 50%
    • Medicare patients:
      • QP threshold increasing from 35% to 50%
      • Partial QP threshold increasing from 25% to 35%
    • QPs will receive a higher Medicare physician fee schedule (PFS) update (“qualifying APM conversion factor”) of 0.75% compared with non-QPs, who will receive a 0.25% Medicare PFS update, which will result in a differentially higher PFS payment rate for eligible clinicians who are QPs.

More details from CMS are available in the 2024 Quality Payment Program fact sheet and Frequently Asked Questions.

AASM members can send questions about the CMS Quality Payment Program to