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.
Improvement Activities Performance Category
Two existing Improvement Activities have proposed modifications:
- IA_BE_4 Engagement of patients through implementation of improvements in patient portal
- IA_AHE_7 Comprehensive Eye Exams
Promoting Interoperability Performance Category
Proposed changes include retention of the measure as an optional measure worth 10 bonus points and the addition of an optional Health Information Exchange bidirectional exchange measure.
Cost Performance Category
The CMS is proposing to add telehealth services directly applicable to existing episode-based cost measures and the total per capita cost measure.
These are key takeaways from the proposed rule; this is not a comprehensive list of all proposed changes. The ACR will comment on the proposed rule on behalf of the specialty. Members may submit their comments to the ACR Advocacy team or comment to the CMS directly. The CY 2021 final rule is expected to be released in November 2020. Additional information about the PFS NPRM and the QPP proposals is available in the press release and a fact sheet on the QPP proposed policies for 2021 that compares these policies to the current 2020 requirements.
Contact the Quality Payment Program at 1-866-288-8292 or by email at QPP@cms.hhs.gov.
ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE registry at 404-633-3777 or by email at RISE@rheumatology.org.