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CMS 2021 Benchmark Updates May Impact Your Quality Improvement Process

By: Courtney Tesvich | June 30th, 2021

CMS 2021 Benchmark Updates May Impact Your Quality Improvement Process Blog Feature

On June 11, 2021, CMS released updated 2021 quality benchmarks via email. This blog post will provide an overview of quality benchmarks, impact of recent changes and tips on how to optimize your quality reporting in 2021 despite the changes. Additionally, we will explain these updates as well as how they will affect your Quality Improvement process for 2021.

Quality Benchmarks Explained

Benchmarks are the basis for your performance score in the MIPS Quality Category. CMS takes the performance from two years prior to the reporting period and separates that performance into deciles. The decile that matches your performance in the reporting year, determines your score for the measure. For example, let’s project you will achieve 84 percent performance in 2021 for the Pneumococcal Vaccination Status for Older Adults measure. The below chart is an example of CMS’ Quality Benchmarks for this measure (CMS 111).

For 2021, 85 percent performance will earn you at least 9 points (with a range of 9-9.9) when reporting via the Direct EHR (eCQM) Collection Type. Benchmarks help to make informed decisions about your quality reporting. In addition to helping identify your reporting score, the benchmarks can help determine the most favorable way to report.

Again, looking at the chart above, your provider(s) will get 9 points for reporting the measure as an eCQM. But, if they reported the measure through a registry (MIPS CQM collection type), that same performance rate would earn you only 8 points making Direct EHR reporting the more favorable option in this case. Thus, it is important to understand and use the benchmarks as a tool to facilitate maximizing your quality score.

Impact of Recent Changes

CMS stated in their June 11th newsletter that these updates were released to correct an error with the decile margins. Essentially, the margins were off by one decile across all the measures in their initial release of the 2021 benchmarks. If you were tracking your quality performance using the original benchmark file, the result of the change is that your performance rate for each measure will be one decile lower than you expected. CMS stated they wanted to be transparent about the discrepancy and assume responsibility for the error in the initial file.

It is important to note that there are also several quality measures that do not have benchmarks for 2021. Any measure that does not have a benchmark for 2021 will only get a maximum of 3 points (plus any applicable bonus points).

Optimizing Your 2021 Quality Reporting

As you embark on the second half of the reporting year, it is important to know what you can do and the resources available to ensure you maximize your quality performance score. Here are some tips to consider:

  1. Download and review the benchmarks from the QPP Resource Library
    • As stated earlier, tracking your performance and your project score throughout the year can help you make informed decisions about which measures you decide to report.
  2. Know that you can report across multiple collection types
    • For clients also engaging with registries to report quality, you can report some measures from the registry and some from your EHR. CMS will score you the highest performing 6 measures from multiple submission methods (i.e., Direct EHR, Registry, or Claims (for small practices only).
  3. Understand advantage of Direct EHR reporting
    • In most cases, when reporting via Direct EHR or reporting to registry directly from your EHR, you qualify for electronic end-to-end reporting bonus points (1 point per measure submitted electronically).
  4. Get help from Regulatory Experts
    • Check with your EHR vendor to see if they have a team of experts to help you review your performance regularly and help put you on the best path to increased performance for 2021. 

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