• Innovation in Action

Dec 3, 2020

CMS Releases 2021 QPP Final Rule

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The Centers for Medicare & Medicaid Services (CMS) recently released the final policies for the Quality Payment Program (QPP) 2021 Performance reporting year. CMS outlines updates to the Quality Payment Program including Merit-based Incentive Payment (MIPS) Program Value Pathways (MVPs) and finalizes the Alternative Payment Model (APM) Performance Pathway (APP) and addresses COVID-19 Public Health Emergency (PHE) considerations.

Please see details here: 2021 Physician Fee Schedule (PFS) Final Rule

Summary of the Calendar Year (CY) 2021 Final Rule

This review will focus specifically on MIPS

Changes Regarding Participation

  • In response to the COVID-19 PHE, MVPs will not be introduced in 2021 as originally proposed and will be available during the 2022 reporting year
  • Implementation of Advanced the APP
    • Only available to participants in a MIPS APM
    • Acts as pathway to MVPs with a fixed set of measures for each performance category
    • Expands the use of the APM Entity submitter Type to allow its use for all MIPS Submission Mechanisms.
    • The Cost performance category will be weighted at 0% since all MIPS APM Participants already are responsible for cost containment under their respective APMs.
  • Sunsetting of the APM Scoring Standard for the 2021 performance period
    • As a result, the APM Entity Type was added as a submitter type which may report to MIPS on behalf of associated MIPS Eligible Clinicians (ECs).
      • In previous years, ECs under an APM entity that is both an Advance and MIPS APM that are not Qualified or Partial Qualifying APM Participant were scored under the APM Scoring Standard which had different performance category weights than the traditional MIPS Scoring weights that non APM ECs have used.
      • This change, will allow MIPS ECs in APMs to participate in MIPS and submit data as individuals, as part of a group or virtual group, or through their APM Entity
      • The Cost performance category will be waived and weighted to 0% if the APM Entity reports under traditional MIPS as opposed to reporting through the APP
        • However, when an APM Entity selects to report to traditional MIPS, CMS will continue to calculate a Promoting Interoperability performance category score for the APM Entity based on data submitted at the individual and group levels.

Performance Threshold and Performance Category Weights for individual MIPS ECs, groups, and virtual groups reporting traditional MIPS

  • The performance threshold will be kept at 60 points for 2021
  • The Quality performance category to be weighted at 40% (5% decrease from Payment Year (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)

Quality Performance Category

  • Addressed substantive changes to 113 existing MIPS quality measures includes modifications, removals, and additions to Specialty Sets and Quality Measures
    • Removed 11 quality measures from the MIPS program (including All-Cause Hospital Readmission measure) Removals targeted extremely topped out measures
  • Two new administrative claims-based measures (Includes Hospital Wide Readmission measure)
  • Refer to CY 2021 PFS Final Rule-Appendix I: Table Groups A, B, C, and D for details
  • Revises scoring flexibility for measures with specification or coding changes during the performance year
  • Sunsetting of the CMS Web Interface but extending the availability as a collection and submission type for one year for the 2021 performance period due to the COVID-19 PHE
    • Transition to an alternate collection and submission solution will start in 2022

Cost Performance Category

  • Updated 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
  • Weighting of the Cost performance category at 20% for individuals, groups, and virtual groups reporting traditional MIPS
  • Weighting the Cost performance category at 0% for APM Entities reporting traditional MIPS

Improvement Activities (IA) Performance Category

  • Modified two existing IA’s and removed one that was deemed to be obsolete (CC_5: CMS Partner in Patients Hospital Engagement Network)
  • Continues the COVID-19 clinical data reporting IA
  • Established 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
  • Added 1 new criterion for nominating a new improvement activity

Promoting Interoperability (PI) Performance Category

  • Retained the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure and finalized to make it worth 10 bonus points
  • Finalized to change the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information by replacing “incorporating” with “reconciling”
  • Added an optional Health Information Exchange (HIE) bi-directional exchange measure as an alternate reporting option to the two existing measures for the HIE objective
  • Updated certified electronic health record technology (CEHRT) requirements in response to the ONC 21st Century Cures Act Final Rule

Scoring and COVID-19 Flexibilities for 2021

  • Finalized change to double the number of points available for the complex patient bonus to account for the additional complexity of treating patients during the COVID-19 PHE
    • Clinicians, groups, virtual groups, and APM Entities could now earn up to 10 bonus points toward their final score for the 2020 performance year
  • APM Entities allowed to apply to reweight MIPS performance categories as a result 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.

Resources

If you need assistance with any questions about MIPS or the 2021 Final Rule, HQI is here to assist you. Please reach out to us if needed:

www.hqi.solutions

Main Office: 804.289.5320