What to Know: 2021 Quality Payment Program (QPP) Final Rule and MIPS

It’s that time of year again… time to make decisions regarding the Quality Payment Program (QPP) and Merit-based Incentive Payment System (MIPS) for 2021. Payments in 2023 (based on 2021 data) are scheduled to have a potential positive/negative adjustment of ±9. With so much reimbursement at stake and so much information about categories and measures, making MIPS decisions can be overwhelming. We’ve put together a quick overview of changes for 2021 to help guide your way.

MIPS Reporting

Merit-based Value Pathways set to begin this year have been postponed until 2022 due to COVID. Therefore, providers can report data through the traditional Merit-based Incentive Payment System (MIPS) and the new APM Performance Pathway (APP). The APP is a new reporting framework that is complementary to MIPS Value Pathways (MVPs). The new APP is available to eligible clinicians, groups, or APM Entities that participate in MIPS APMs. According to the American College of Physicians, clinicians participating in APP are likely to fall into one of two scenarios: “1) their model does not meet the criteria to be considered an ‘Advanced APM;’ or 2) they fall short of Qualified Advanced APM Participant (QP) Thresholds.”

More about the APM Performance Pathway (APP)

The category score for Improvement Activities will be automatically assigned according to the MIPS Alternative Payment Model (APM) of the participating clinician. All APM participants who report through the APP will earn a 100% score.

The use of the CMS Web Interface to collect data for MIPS using the APP quality measure set will continue for 2021 but will end at the beginning of the 2022 performance period.

The APP quality measures contain:

  • The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS
  • 2 measures calculated by CMS using claims data
  • 3 quality measures reported at electronic clinical quality measures (eCQMS), MIPS CWMS, or Medicare Part B claims measures

 

Traditional MIPS Performance Thresholds and Weights for 2021

The performance threshold for 2021 will be 60 points for individual clinicians, provider groups, and APM Entities reporting traditional MIPS.

The finalized category weights:

Individual and Groups

  • Quality performance: 40% (5% decrease from 2020)
  • Cost performance: 20% (5% increase from 2020)
  • Promoting Interoperability remains at 25%
  • Improvement Activities remains at 15%

APM Entities

  • Quality performance category weight is 50%
  • Cost performance category: 0%
  • Promoting Interoperability: 30%
  • Improvement Activities: 20%

Traditional MIPS Performance categories

There are several finalized policy changes, including:

  • Significant changes to 113 quality measures
  • Removal of 11 quality measures
  • Addition of 2 new administrative claims measures
  • Revised scoring for measures with specification or coding changes

Note: CMS decided they have sufficient information to calculate historical benchmarks. They did not enact the proposal to use performance period benchmarks as the only means to score quality measures in 2021 or to use 2021 performance period benchmarks to decide if a measure is capped at seven points.

 

Promoting Interoperability category:

  • The Query of Prescription Drug Monitoring Program (PDMP) measure remains optional and is worth 10 bonus points
  • ‘Incorporating’ has been replaced with ‘reconciling’ for the Support Electronic Referral Loops by Receiving and Incorporating (now Reconciling) Health Information
  • A new, bi-directional exchange measure has been added as an alternative reporting option to the existing Health Information Exchange (HIE) measures.
  • Certified electronic health record technology (CEHRT) requirements are updated according to the ONC 21st Century Cures Act Final Rule

 

Policy changes to Cost and Improvement Activities Performance categories

MIPS has updated existing Cost Performance measure specifications to include telehealth services. One activity has been removed, and two other activities modified for Improvement Activities.  COVID-19 clinical data reporting continues with the modifications outlined in the September Interim Final Rule with Comment (IFC)

Helpful Information

  • Find information about available MIPS measures and categories here.
  • Registration for reporting via the CMS Web Interface for 2021 is between April 1 – June 30. Learn more about registration here.
  • Qualifying Participant Determination is available in July here.
  • October 3, 2021 is the last day to start a 90-day Performance Period for Promoting Interoperability and Improvement Activities.
  • The submission window for PY 2021 opens on January 3, 2022

Trying to keep up with MIPS categories, measures and reporting can be overwhelming – using the right partner for practice management software and billing makes it easy. Contact us today at (412) 424-2260 or visit https://vowhs.com/athenaone/. to learn how we can help optimize MIPS, streamline claims, and maximize revenue.

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