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Aug 10, 2020

CMS Proposes Updates to Quality Payment Program (QPP) for 2021 Performance Reporting Year


The Centers for Medicare & Medicaid Services (CMS) recently released their proposed Quality Payment Program (QPP) rules for the 2021 Performance reporting year. In the proposal, CMS also outlines the future direction of the QPP including proposed Merit-based Incentive Payment System (MIPS) Value Pathways (MVP) and introduces the Alternative Payment Model (APM) Performance Pathway (APP).

Please see details here: 2021 QPP Proposed Rule Fact Sheet

The following review of CMS’ proposed changes focuses specifically on MIPS

Summary of CY 2021 Proposals


  • Expand the use of the APM Entity submitter type to allow the use of all MIPS submission mechanisms.
    • MIPS-eligible clinicians can continue to participate as individuals, as part of a group or virtual group
  • End APM Scoring Standard beginning with the 2021 performance period
  • MIPS Value Pathways (MVPs) will not be introduced in 2021 and will not be available until the 2022 reporting year
  • Advanced Alternative Payment Model (APM) Performance Pathway (APP) will only be available to participants in a MIPS APM

Performance Threshold and Performance Category Weight

  • The performance threshold to be 50 points
  • The Quality performance category to be weighted at 40% (5% decrease from PY 2020)
  • The Cost performance category to be weighted at 20% (5% increase from PY 2020)
  • The Promoting Interoperability performance category to be weighted at 25% (no change from PY 2020)
  • The Improvement Activities performance category to be weighted at 15% (no change from PY 2020)

NOTE: In the CY 2020 PFS Final Rule, CMS finalized a performance threshold of 60 points for the 2021 performance period but are proposing and soliciting comment on a lower performance threshold of 50 points.

Quality Performance Category

  • Use performance period, not historical, benchmarks to score quality measures for the 2021 performance period.
  • Update the scoring policy for topped-out measures,
  • Remove 14 quality measures from the MIPS program
  • 206 quality measures starting in the 2021 performance year
    • Two new administrative claims-based measures, one of which has a 3-year measurement period.
  • Revise scoring flexibility for measures with specification or coding changes during the performance year
  • End CMS Web Interface as a quality reporting option for ACOs and registered groups, virtual groups, or other APM Entities beginning with the 2021 performance period.
    • Select their own quality measures instead of a pre-determined set of measures established under the CMS Web Interface.
      • Ability to select measures more meaningful to their scope of practice, including specialty specific measures, would better prepare them for implementation of MVPs.
      • Report fewer measures (6 as opposed to 10) with the ability to report on all-payer data.
      • Have the option to report the eCQM or MIPS CQM version of the same primary care measures previously reported through the CMS Web Interface.

Cost Performance Category

  • Update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the Total Per Capita Cost (TPCC) measure.

Improvement Activities Performance Category (IA)

  • Make minimal updates to the Improvement Activities Inventory.
  • Establish policies in relation to the Annual Call for Activities including an exception to the nomination period timeframe during a public health emergency (PHE) and a new criterion for nominating new improvement activities
  • Establish a process for agency-nominated improvement activities

Promoting Interoperability Performance Category (PI)

  • Retain the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure and propose to make it worth 10 bonus points.
  • Change the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information by replacing “incorporating” with “reconciling.”
  • Add an optional Health Information Exchange (HIE) bi-directional exchange measure


  • Change the maximum number of points available for the complex patient bonus to account for the additional complexity of treating patients during the COVID-19 Public Health Emergency.
  • Clinicians, groups, virtual groups, and APM Entities could now earn up to 10 bonus points toward their final score for the 2020 performance year. (Proposal is for the 2020 Performance year only)
  • Allow APM Entities to apply to reweight MIPS performance categories because of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. This policy would apply beginning with the 2020 performance period.

Public Comment Opportunity

The proposed rule includes directions for submitting comments. Comments must be received within the 60-day comment period, which closes on October 1, 2020. When commenting, refer to file code: CMS-1734-P

Use one of the following ways to officially submit your comments:

  • Electronically through Regulations.gov
  • Regular mail
  • Express or overnight mail
  • No Faxes

2019 MIPS Performance Feedback and Final Score

We encourage you to log into your QPP portal (cms.gov.login) to review your feedback reports and if you feel an error has been made to your calculated MIPS payment adjustment, you can request a targeted review until October 5, 2020.

Please download the 2019 Targeted Review User Guide to learn more.

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