2021 QPP Proposed Rule

CMS recently published the CY 2021 Quality Payment Program (QPP) Proposed Rule which included numerous updates to the Merit-based Incentive Payment System (MIPS) for 2020 reporting and subsequent reporting years, with a focus on 2021 reporting. For the full text of the rule, see the Federal Register.

MIPS Value Pathways (MVPs)

MIPS Value Pathways (MVPs) were originally finalized to begin with the 2021 reporting year, but CMS did not propose any MVP candidates in this ruling and thus has proposed to not make MVPs available for MIPS reporting until the 2022 performance period, or later. CMS plans to have an MVP development webinar to review MVP development criteria, timeline, and process to submit a candidate MVP. Stakeholders would submit their candidate MVPs using a standardized template and MVPs would be established through rulemaking.

APM Performance Pathway (APP)

Beginning with 2021 reporting, CMS is proposing a new pathway complementary to MVPs, the APM Performance Pathway (APP). The APP would only be available to participants in MIPS APMs and would be required for Medicare Shared Savings Program (MSSP) quality determinations for ACOs. Like an MVP, the APP would be comprised of a fixed set of measures for each performance category. Since MIPS APM participants are responsible for cost containment under their APMs, the Cost performance category would be weighted at 0%. Further, for the Improvement Activities Category, all APM participants would automatically receive a score of 100% for the 2021 performance period. The Promoting Interoperability performance category would be reported and scored the same as it is for the rest of MIPS. Lastly the Quality performance category would include 6 measures that focus on population health and be applicable to all APM participants. In this proposed framework Quality would be weighted at 50%, PI at 30%, IA at 20%, and Cost at 0%.

MIPS Performance Categories

Quality

CMS is proposing to use performance period benchmarks for the CY2021 MIPS performance period, rather than using historic data. In other words, the benchmarks for CY2021 would be based on the data submitted during the CY2021 performance period. CMS’ reasoning for this proposal is there may not be a representative sample of historic data from CY 2019 reporting because COVID-19 impacted data submission in 2020. In relation to this proposal, beginning with the 2021 performance period, CMS is proposing to apply a cap of 7 achievement points to measures that are topped out for 2 or more consecutive years including the 2021 MIPS performance period benchmarks.

CMS is also proposing 2 administrative claims measures for the Quality performance category. The first proposed measure is the Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate, which would replace the All-Cause Hospital Readmission Measure. The second proposed measure is the Risk-Standardized complication rate (RSCR) following elective primary total hip arthroplasty (THA) and/or total knee arthroplasty (TKA). While the first measure would only apply to groups with 16 or more clinicians that meet the case minimum of 200 cases, the second measure would apply to all individuals and groups that meet the case minimum of 25 cases.

Lastly, CMS is proposing to remove the CMS Web Interface as a collection and submission type for groups beginning with the 2021 performance period.

Cost

CMS proposes to add costs associated with telehealth services that are directly relevant to the existing episode-based cost measures and the Total Per Capita Cost (TPCC) measure. CMS has made the updated measure specifications with the added telehealth codes available on the MACRA feedback page.

Promoting Interoperability

CMS is proposing to retain the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure and propose to make it worth 10 bonus points. In addition, CMS is proposing to change the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information by replacing “incorporating” with “reconciling”. The new name of the measure would be Support Electronic Referral Loops by Receiving and Reconciling Health Information, which more accurately represents the actions of the measure’s numerator, such as when no update or modification is needed within the patient record based on the electronic clinical information received. Lastly, CMS is proposing to add an optional Health Information Exchange (HIE) bi-directional exchange measure, which would be a Yes/No attestation measure. Individuals and groups would be able to attest to this measure in place of HIE 1 and HIE 4. To meet this measure, the clinician’s EHR would need to be enabled to allow for querying and sharing data by sending, receiving, and incorporating data via an HIE for every patient.

Improvement Activities

CMS is proposing modifying 2 existing Improvement Activities for 2021 performance period. Further, CMS is proposing that beginning with the 2021 performance period, new improvement activities that are nominated for inclusion in the program can be linked to existing and related MIPS quality and cost measures.

MIPS Scoring, Performance Threshold, and Payment Adjustments

For 2021 MIPS reporting, the final MIPS score will be based on the four performance categories and their corresponding weights. While the category weight of Promoting Interoperability and Improvement Activities are proposed to remain the same, cost is proposed to increase by 5% while quality would decrease by 5%. By law Cost & Quality must be equally weighted at 30% beginning with 2022 performance period.

• Cost: 20%
• Quality: 40%
• Promoting Interoperability: 25%
• Improvement Activities: 15%

For 2021 reporting, the performance threshold is proposed to be 50 points, as opposed to the previously finalized performance threshold of 60 points, and the exceptional performance threshold will remain at 85 points, as previously finalized.

Complex Patient Bonus

For the 2020 performance period, CMS is proposing to double the complex patient bonus allowing individuals and groups to earn up to 10 bonus points, instead of 5, on the MIPS score to account for a more complex patient population due to COVID-19.

If you have questions about MIPS or need help with your MIPS reporting, please contact us.