CMS continues to phase in the Quality Payment Program while MACRA mandates loom.
The long-awaited Physician Fee Schedule (PFS) final rule, now pending publication in the Federal Register, finalizes proposed updates to the Quality Payment Program (QPP) and its two tracks — the Merit-Based Incentive Payment System (MIPS) and Advanced Alternate Payment Models (APMs) — for performance year 2021. Recognizing the burden the COVID-19 pandemic has placed on healthcare providers this year, the Centers for Medicare & Medicaid Services (CMS) is not finalizing some of its weightier proposals, such as implementing MIPS Value Pathways (MVPs), and is incorporating added flexibilities.
MVP Policy Guidelines and Development Criteria
Although clinicians need not worry about adopting MVPs for reporting in MIPS this coming year, the concept is not going away. CMS says in the final rule that they are “moving forward” with policy development and only delaying the start date “until at least the 2022 performance year.” With that, CMS is finalizing several changes to existing MVP guiding principles and development criteria.
CMS is clarifying that MVPs should consist of not just limited sets of measures and activities, but “connected, complementary sets of measures and activities” that are meaningful to clinicians; and MVPs should include measures selected using the “Meaningful Measures approach and, wherever possible, the patient voice must be included.” CMS is adding a fifth guideline, as well: “MVPs should support the transition to digital quality measures, to the extent feasible.”
The final rule goes on to outline several MVP development criteria and the process for candidate MVP collaboration, solicitation, and evaluation. CMS plans to hold a public-facing MVP Solicitation Kick-Off webinar to review MVP development criteria, timelines, and processes in which to submit an MVP candidate.
APM Performance Pathway on Track
Unlike MVPs, the APM Performance Pathway (APP) is being finalized for performance year 2021. This new track is only available to MIPS eligible clinicians, groups, or APM entities participating in MIPS APMs. Medicare Shared Savings Program (MSSP) accountable care organizations (ACOs) will be required to use the APP. Quality scores for ACOs that are reported through the APP can also be used for MSSP.
Like MVPs, the APP will be comprised of a fixed set of measures for each MIPS performance category. Performance category weights for APM entities reporting MIPS for the 2021 performance year are:
- Quality – 50%
- Cost: 0%
- Promoting Interoperability – 30%
- Improvement Activities – 20%
For the 2021 performance year, all APM participants that successfully report the APP will receive full credit in the Improvement Activities performance category. The performance threshold will remain 60 points for APM entities.
Veering from the MIPS you know and love, the APP will have a quality measure set of three electronic clinical quality measures (eCQMs), MIPS CQMs, or Medicare Part B claims measures; a Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey measure; and two measures that CMS will calculate using administrative claims data.
CMS is extending for one year the use of the CMS Web Interface as a collection type for MIPS during the 2021 performance period. As such, for 2021 only, ACO participants can report the 10 CMS Web Interface measures in place of the three eCQMs/MIPS CQMs in the APP.
What Will MIPS Participation Look Like in 2021?
2020 has not been business as usual for anyone, anywhere. CMS acknowledged this by activating an exception for eligible clinicians for performance years 2019, 2020, and 2021. CMS also added scoring flexibilities by expanding the list of reasons a quality measure may be impacted and suppressing measures affected by significant code changes.
One change to MIPS participation options is that all MIPS eligible clinicians, including those in a MIPS APM, may choose to participate in MIPS as an individual, a group, a virtual group, or an APM entity. For the 2020 performance year, eligible clinicians in a MIPS APM were required to participate through their APM entity under the APM scoring standard, but the APM scoring standard will no longer be used beginning with the 2021 performance year.
Final Performance Category Weights
For individuals, groups, and virtual groups reporting in MIPS for the 2021 performance year, the performance category weights are:
- Quality – 40%
- Cost – 20%
- Promoting Interoperability – 25% (no change)
- Improvement Activities – 15% (no change)
Collection types for quality measures remain the same as in 2020, but there are “substantive” changes to 113 existing MIPS quality measures, including the removal of the All-Cause Hospital Readmission measure and the addition of two new administrative claims measures.
There are not too many changes to measures in the other categories. CMS is continuing the COVID-19 clinical data reporting improvement activity, for which most practices will earn an easy A-plus. In the Cost performance category, CMS is adding telehealth services to existing episode-based and Total Per Capita Cost (TPCC) measures.
Note: For the 2020 performance period, CMS is doubling the complex patient bonus APM entities can earn to 10 points to account for COVID-19.
The performance threshold for performance year 2021 is 60 points, as finalized previously; and the exceptional performance threshold remains 85 points one last year before CMS discontinues it.
Important MIPS Dates and Deadlines
Dec. 31 – The 2020 Promoting Interoperability Hardship Exception Application period closes.
Dec. 31 – The 2021 virtual group election period closes.
Jan. 4, 2021 – The 2020 MIPS performance year data submission window opens.
March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category.
March 31, 2021 – The 2020 MIPS performance year data submission window closes.
Advanced APM Changes for 2021
Because of the pandemic, CMS is recognizing the Shared Savings Program extreme and uncontrollable circumstances policy for all ACOs for the 2020 performance period. CMS is also waiving the requirement for ACOs to field a CAHPS for ACOs Survey and is awarding full credit.
For next year, CMS is making one change for determining Qualifying APM Participant (QP) threshold scores, and they will accept targeted review requests of QP determinations beginning in 2021 under “limited” circumstances.
Also, for performance years 2021 and 2022, ACOs can meet the Shared Savings Program quality performance standard if they achieve a quality performance score equal to or more than the 30th percentile across all MIPS Quality performance category scores. In 2023, ACOs will have to achieve a quality performance score equal to or more than the 40th percentile to meet the standard.