The Centers for Medicare and Medicaid Services (CMS) recently released its proposed 2021 Medicare Physician Fee Schedule. Among the proposed items are a number of significant changes to the Quality Payment Program (QPP) for next year. To make sure your practice knows what to expect with these new changes, here is a list of just some of the more notable items:
- Overall, the proposed rule addresses changes to 112 existing MIPS quality measures, removes 14 and proposes 206 new ones that will begin in 2021.
- In 2021, the proposed performance threshold will be 50 points (up from 45 points in 2020) and exceptional performance will be 85 points (up from 80 points in 2020).
- A proposal to delay the implementation timeline for MIPS Value Pathways (MVPs) until the 2022 performance period has been made. CMS also proposes additions to guiding principles and development criteria that will support stakeholder engagement in codeveloping MVPs and establishing a path for MVP candidates to be recommended through future rulemaking.
- The Introduction of Alternative Payment Model (APM) Performance Pathway (APP) to align with the MVP framework has been made. As part of APP implementation, the CMS Web Interface will be sunset as a collection type at the start of the 2021 performance period.
- CMS is currently accepting comments on a lower performance threshold of 50 points (down from 60 points in 2020).
- Performance category weight increases have been proposed (up 5 percent from 2020):
- An increase in the Quality performance category to 40 percent in 2021
- An increase in the Cost performance category to 20 percent in 2021
- Promoting Interoperability would stay at 25 percent
- Improvement Activities would stay at 15 percent
- There is a proposal to reduce the total Accountable Care Organization (ACO) quality measure set from 23 measures to 6 measures, and the number on which ACOs are required to actively report would be reduced from 10 to 3
- There is a proposal to end the APM Scoring Standard at the start of the 2021 performance period, as well as to add the APM Entity as a submitter type which may report to MIPS on behalf of associated MIPS eligible clinicians.
- Another proposal would use performance period benchmarks (not historical) to score quality measures for 2021. The 7-measure achievement point cap would be applied only if a measure is identified as “topped out” based on the established benchmarks for both the 2020 and 2021 performance periods.
2020 has been a year of changes to say the least, and it looks as though 2021 will see many more when it comes to QPP and MIPS. However, by staying well informed and being prepared ahead of time, your practice can continue toward another successful year of MIPS attestation. The CMS Final Rule for 2021 should be released around early November, and we will update readers on finalized provisions when the time comes. Subscribe and stay tuned to our blog for more regulatory updates.
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