The Centers for Medicare and Medicaid Services (CMS) has released the Quality Payment Program (QPP) proposed rule for the 2021 performance year. To accommodate for the challenges posed by COVID-19, CMS is not proposing many significant changes to the Merit-based Incentive Payment System (MIPS) for 2021. Here are the highlights of the proposed rule for next year. For information on the current performance year, see our MIPS 2020 page.
MIPS Value Pathways
Introduction of MIPS Value Pathways (MVPs), the new framework originally set to begin implementation in the 2021 performance year, will be postponed. CMS will continue to work on engaging stakeholders and developing the framework’s guiding principles.
APM Performance Pathway
CMS has proposed an APM Performance Pathway (APP), complementary to MVPs. This option would be available to MIPS APM participants only and would be composed of a fixed set of measures for each performance category. The APP performance measures would also satisfy reporting requirements for the Medicare Shared Savings Program quality scoring.
Performance Category Weights
In 2021, the proposed Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.
For the 2021 performance period, CMS proposes to increase the performance threshold (maximum number of points needed to avoid a negative payment adjustment) from 45 to 50 points. There is no change to the exceptional performance threshold (number of points needed for a positive payment adjustment) of 85 points.
CMS proposes to use performance period benchmarks, rather than historical, to score quality measures. Previously, the benchmarking baseline period was the 12-month calendar year two years prior to the MIPS performance year. CMS hopes to ensure accurate and reliable data due to possible gaps in baseline data due to COVID-19. Therefore, in 2021, the agency proposes to use benchmarks from the 2021 performance period instead of the 2019 calendar year.
CMS also proposes to end the 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.
Improvement Activities Category
Minimal updates would be made to the Improvement Activities inventory. A process would also be established for agency-nominated improvement activities.
In 2021, there are no proposed changes to the requirement that at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.
CMS proposes to update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the TPCC measure.
COVID-19 Flexibility Scoring Proposals
For the 2020 performance period only, the maximum number of bonus points available for the complex patient bonus would be 10, to account for the additional complexity of treating patients during the COVID-19 public health emergency.
You can view the full 2021 QPP Proposed Rule fact sheet here.
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