On Aug. 3, 2020, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2021 performance year of the Quality Payment Program (QPP) included in the CY 2021 Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM). The ACR RISE registry staff has reviewed and highlighted key proposed policies for the 2021 Merit-Based Incentive Payment System (MIPS) reporting period and how they compare to the current 2020 MIPS reporting period.
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According to the CMS, “In recognition of the 2019 Coronavirus (COVID-19) public health emergency and limited capacity of healthcare providers to review and provide comment on extensive proposals, CMS has limited annual rulemaking required by statute to focus primarily on essential policies including Medicare payment to providers, as well as proposals that reduce burden and may help providers in the COVID-19 response.”
Of note, the proposed changes continue a gradual implementation of category re-weighting and increase to the performance threshold for 2021. By continuing the gradual increases in 2021, providers will see significant shifts in 2022: 30% weighting for the Quality and Cost categories and a performance threshold near 75 points as required by the Medicare Access and CHIP Reauthorization Act of 2015.
The proposed changes are not finalized until the CMS announces the final rule, expected in November. The ACR will review and evaluate the final rule once announced and will provide more information at that time on the impact for practices.
Performance Category Weights
- Quality: 40% for CY 2021 (45% for CY 2020)
- Cost: 20% for CY 2021 (15% for CY 2020)
- Promoting Interoperability: 25% (no change from CY 2020)
- Improvement Activities: 15% (no change from CY 2020)
- Performance threshold at 50 points (45 points for CY 2020)
- 85 points for exceptional performance (no change from CY 2020)
Quality Performance Category Collection Types
The CMS is proposing to remove the CMS Web Interface as a collection type and submission type for groups and virtual groups. There are no other changes from CY 2020.
MIPS Participation and Reporting
The CMS is proposing that all MIPS-eligible clinicians, including those in a MIPS Alternative Payment Model (APM), may choose to participate in MIPS as an individual, a group, a virtual group or an APM Entity. The CMS is also proposing to end the APM Scoring Standard beginning with the 2021 performance period.
Quality Measure Benchmarks
The CMS intends to use data submitted during the CY 2021 performance period, rather than the CY 2019 performance period, to benchmark CY 2021 data. This decision is due to concerns that the national public health emergency for COVID-19 impacted data submission in 2020, resulting in a non-representative sample of historic data for CY 2019 that could skew benchmarking results.