Posted on August 20, 2020
On August 4, 2020, the Centers for Medicare and Medicaid Services (CMS) released its proposed regulation for the Quality Payment Program (QPP) with recommended changes to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) in 2021 and beyond. A final rule will be released later this fall after a public comment period. Here is a look at some key highlights of the proposed changes and how they could impact your practice.
Quality and Cost Performance Category Weight Changes
The following changes are proposed to the MIPS performance category weights:
*These weights would not apply to the new APP.
Minimum Threshold and Payment Adjustments
CMS is proposing to only increase the minimum threshold to 50 points (up from 45 points in 2020) for the new performance year. This means you must achieve at least 50 MPS points to avoid any penalty. The additional performance threshold for exceptional performance would remain the same at 85 points. There would also be no changes to the MIPS payment adjustments which would stay at +/- 9%.
Quality Performance Category
For the Quality category, worth up to 40% of your MIPS score, you would continue to report 6 measures on at least 70% of your eligible patients for the entire year. At least 1 of the 6 measures should be an Outcome or High Priority measure. Proposed changes to this category include:
Changes would be made to 112 existing Quality measures and some specialty measure sets. There would be 2 new administrative claims measures added for 2021:
- Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups.
- Risk-standardized complication rate (RSCR) following elective primary total hip arthroplasty (THA) and/or total knee arthroplasty (TKA) for MIPS Eligible Clinicians.
The following 14 measures are proposed for removal from the MIPS program beginning in 2021:
|Quality Measures Proposed for Removal in 2021|
|#024||Communication with the Physician or Other Clinician Managing On-Going Care Post-Fracture for Men and Women Aged 50 Years and Older|
|#048||Urinary Incontinence: Assessment of Presence or Absence of Urinary Incontinence in Women Aged 65 Years and Older|
|#069||Hematology: Multiple Myeloma: Treatment with Bisphosphonates|
|#146||Radiology: Inappropriate Use of “Probably Benign” Assessment Category in Screening Mammograms|
|#333||Adult Sinusitis: Computerized Tomography (CT) for Acute Sinusitis (Overuse)|
|#337||Psoriasis: Tuberculosis (TB) Prevention for Patients with Psoriasis, Psoriatic Arthritis and Rheumatoid Arthritis Patients on a Biological Immune Response Modifier|
|#348||Implantable Cardioverter-Defibrillator (ICD) Complications Rate|
|#390||Hepatitis C: Discussion and Shared Decision Making Surrounding Treatment Options|
|#408||Opioid Therapy Follow-up Evaluation|
|#412||Documentation of Signed Opioid Treatment Agreement|
|#414||Evaluation or Interview for Risk of Opioid Misuse|
|#435||Quality of Life Assessment For Patients With Primary Headache Disorders|
|#437||Rate of Surgical Conversion from Lower Extremity Endovascular Revascularization Procedure|
|#458||All-Cause Hospital Readmission (Administrative Claims measure)|
CMS would use performance period, not historical, benchmarks to score quality measures for the 2021 performance period based on concerns they may not have a representative sample of historic data for CY 2019 due to the COVID-19 pandemic.
The scoring policy for topped-out measures would be updated so that the 7 point cap would be applied only if the measure is identified as topped out based on the established benchmarks for both the 2020 and 2021 performance periods due to the proposed benchmark changes.
Revised scoring flexibility
CMS would revise the scoring for measures with specification or coding changes during the performance year. In these cases, CMS would either:
- Truncate the performance period to 9 consecutive months if there were no concerns with potential patient harm and 9 consecutive months of data were available; or
- Suppress the measure from scoring (0 achievement points and total measure achievement points reduced by 10 for each measure submitted that is impacted) if 9 consecutive months of data were not available.
Cost Performance Category
The Cost Category would be worth 20% of your MIPS score in 2021. CMS would maintain the existing Cost measures:
- TPCC measure
- MSPB Clinician measure (no change from CY2020)
- 18 existing episode-based cost measures
CMS proposes to also add telehealth services directly applicable to existing episode-based cost measures and the TPCC measure.
Improvement Activities Category
There would be no significant changes to this category, worth up to 15% of your MIPS score. CMS proposes to modify 2 activities for 2021:
- IA_BE_4 Engagement of patient through implementation of improvements in patient portal
- IA_AHE_7 Comprehensive Eye Exams
Promoting Interoperability (PI) Performance Category
The PI category would continue to be worth 25% of your total MIPS Score. CMS proposes the following changes:
- The Query of PDMP measure would remain as an optional measure and would be worth 10 bonus points.
- The name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information measure would be changed by replacing “incorporating” with “reconciling”.
- An optional Health Information Exchange (HIE) bidirectional exchange measure would be added.
- The automatic reweighting policies for the following clinician types would be preserved in 2021:
- Nurse Practitioners (NPs)
- Physician Assistants (PAs)
- Certified Registered Nurse Anesthesiologists (CRNAs)
- Clinical Nurse Specialists (CNSs)
- Physical Therapists
- Occupational Therapists
- Qualified Speech-language Pathologist
- Qualified Audiologists
- Clinical Psychologists Registered Dieticians or Nutrition Professionals
Complex Patient Bonus
For the 2020 performance period only: CMS proposes to double the complex patient bonus so that clinicians, groups and APM Entities would be able to earn up to 10 bonus points (instead of 5 bonus points) to account for the additional complexity of treating their patient population due to COVID-19.
Web-Interface Reporting Eliminated
CMS will end the CMS Web Interface reporting option for ACOs, registered groups and APM Entities beginning with the 2021 performance period. Groups would be able to select their own quality measures (6 as opposed to 10) instead of reporting on a predetermined set of measures established under the CMS Web Interface.
MIPS APM Reporting Options
MIPS eligible clinicians in APMs would be given the option to participate in MIPS and submit data at the individual, group, or APM Entity level. CMS would also end the APM Scoring Standard (reporting requirements and scoring approach for APM participants) beginning with the 2021 performance period.
CMS is proposing to delay the adoption of the MIPS Value Pathway (MVP) framework until the 2022 performance period or later. The MVP framework was intended to align and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS for different specialties or conditions.
New Alternative Payment Model (APM) Performance Pathway
The APM Performance Pathway (APP) would be created to streamline reporting for APMs and would begin for the 2021 performance year. This proposed pathway is designed to align with the MVP when it is implemented. Proposed features of the APP include:
- A fixed set of quality measures (APP Core Quality Measure Set):
- #1 Diabetes: Hemoglobin A1c (HbA1c) Poor Control
- #134 Preventive Care and Screening: Screening for Depression and Follow-up Plan
- #236 Controlling High Blood Pressure
- #321 CAHPS for MIPS Survey
- Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR)
- Rate Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs
- The Cost performance category would be weighted at 0%.
- The Improvement Activity (IA) performance category score would automatically be assigned based on the IA requirements of the MIPS APM in which the MIPS eligible clinician participates. All APM participants would earn an automatic score of 100% on the IA performance category for the 2021 performance period.
- The Promoting Interoperability performance category would be reported and scored as required for the rest of MIPS.
- QCDRs, Qualified Registries, and Health IT Vendors could support data submission for the program.
How Will This Impact Your Practice?
The changes are only proposed at this time, so we won’t know the final requirements until later this year. The most significant change will be meeting the higher performance threshold of 50 MIPS points to ensure you don’t receive a penalty in 2022, so developing a strong reporting plan is imperative. You should also carefully review the list of Quality measures being proposed for removal to determine if they include measures you have historically reported. If so, you will need to identify other measures you can report for which you have eligible patients in 2021. Another important change to keep in mind affects MIPS APM participants who will have the option to report with a Qualified Registry like MDinteractive next year.
Public Comment Period
CMS will be accepting public comments on the proposed rule until October 5, 2020. A final rule is expected to be issued later in the fall and we will communicate any changes at that time to keep you informed. CMS continues to support MIPS, while introducing improvements to the program for future years. It is important to become familiar with the proposed changes and how they could impact you and your practice in the 2021 performance period. At the same time, you should make sure you have a solid reporting strategy for your 2020 MIPS reporting. We have published many resources on our website to help you with your reporting, but our MIPS specialists are also available to give you more personalized feedback on how to reach your reporting goals.
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2021 MIPS Proposed Rule MIPS Category Weights MVPs MIPS Reporting