On Dec. 1, the Centers for Medicare & Medicaid Services (CMS) released the final rule for the Quality Payment Program (QPP)’s calendar year (CY) 2021 via the Medicare Physician Fee Schedule (PFS) Final Rule.
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The CMS is bound by legal requirements to annually publish final rules updating Medicare payment policies in the PFS. The CMS recognizes the current limited capacity of healthcare providers to review and provide comment on extensive proposals due to the COVID-19 public health emergency. As such, the CMS has limited the required annual rulemaking to focus primarily on essential policies, including Medicare payment to providers, in addition to changes that reduce burden and may help providers in response to COVID-19.
The ACR Rheumatology Informatics System for Effectiveness (RISE) registry staff have reviewed the final rule and highlighted critical policy changes for the 2021 MIPS reporting period.
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 Thresholds
- Performance threshold at 60 points (45 points for CY 2020)
- Additional performance threshold for exceptional performance at 85 points (no change from CY 2020)
The CMS notes that the 2022 performance period/2024 payment year will be the final year of the additional positive adjustment for exceptional performance.
Quality Performance Category Collection Types
There is no change in policy from CY 2020. The CMS is extending the CMS Web Interface as a collection and submission type for both groups and virtual groups through the 2021 performance period. The CMS Web Interface will no longer serve as a collection/submission type beginning with the 2022 performance period.
Merit-Based Incentive Payment System (MIPS) Participation and Reporting
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.
Clinicians in a MIPS APM will be evaluated for MIPS eligibility at the individual and group levels; the CMS will no longer evaluate Entities for the low-volume threshold. The APM Scoring Standard (reporting requirements and scoring approach for APM participants) will not be used beginning with the 2021 performance period.
Quality Measure Benchmarks
There is no change in policy from CY 2020. The CMS has determined that sufficient data were submitted for the 2019 performance period to allow it to calculate historical benchmarks for the 2021 performance period.