The Centers for Medicare & Medicaid Services published the 2023 Quality Payment Program final rule on Nov. 1, 2022. The rule includes provisions addressing the Merit-based Incentive Payment System, MIPS Value Pathways, and Advanced Alternative Payment Models. An analysis of the rule, including key highlights specific to sleep medicine, is included below.

MIPS Value Pathways

To further the goals under the Merit-based Incentive Payment System (MIPS), the final rule includes policies regarding the development of new MIPS Value Pathways (MVPs) and refinement of subgroup participation, revisions to the quality measure and improvement activities inventories, and other policies regarding Alternative Payment Models (APMs) that reduce burden and facilitate participation. CMS has finalized the following for 2023:

  • CMS is expanding the MVP inventory by finalizing 5 new MVPs and revising the 7 previously finalized MVPs to account for the addition of new measures and activities, the removal of measures and activities, and the expansion of an MVP topic that would allow additional specialties to report the MVP.
  • CMS finalized several policies to modify its engagement strategy on MVP development and maintenance.
  • CMS also drafted a Pulmonology MVP, which includes several sleep medicine-specific quality measures, as well as other preventive care measures and improvement activities. The AASM is providing comment on this draft MVP and will alert AASM members if the MVP is finalized.

Merit-based Incentive Payment System (MIPS)

In order to provide clinicians continuity and consistency while they prepare to transition from traditional MIPS to MVPs, CMS limited the number of changes to policies within MIPS for 2023. MIPS will continue to include two sleep-specific measures:

  • Sleep Apnea: Severity Assessment at Initial Diagnosis
  • Sleep Apnea: Assessment of Adherence to Positive Airway Pressure Therapy

The two sleep MIPS measures will continue to be included in the following specialty measure sets:

  • Internal medicine
  • Neurology
  • Otolaryngology
  • Pulmonology

CMS also, once again, approved three AASM Qualified Clinical Data Registry (QCDR) measures:

  • Pediatric OSA: Objective Assessment of Positive Airway Pressure Therapy Adherence
  • Pediatric OSA: Objective Assessment of OSA Signs and Symptoms in Children with Complex Medical Conditions
  • Adult OSA: Screening for Adult OSA by Primary Care Physicians

All AASM quality measures can be reported through Sleep CDR.

Advanced Alternative Payment Models (APMs)

CMS finalized several policies for Advanced APMs:

  • CMS is permanently establishing the 8% minimum Generally Applicable Nominal Risk standard for Advanced APMs, which is currently set to expire in 2024.
  • CMS defined organizational size as measured based on the size of the “parent organization” rather than the size of the APM entity itself.
  • CMS finalized a policy to apply the 50 eligible clinician limit to the APM entity participating in the Medical Home Model based on the TIN/NPIs on the APM entity’s participation list and conforming changes to its Other Payer Advanced APM policies in these areas.

Members may send questions regarding changes to the Quality Payment Program to