MIPS 2021 Proposed Rule: The Road Ahead
CMS released the MIPS 2021 Proposed Rule pertaining to the requirement on August 3rd, 2020. Typically, CMS will review the comments and then release the Final Rule sometime in November of this year. As with the 2019 MIPS Performance Year, the COVID-19 crisis has figured into CMS decision making on what to include in the MIPS 2021 performance year. In several instances it has caused delays in the progression of the program. However, it is evident from the proposed rule that the MIPS program is not going away and will maintain significant negative payment adjustments for non-participation. This blog summarizes the proposed rule for MIPS which is subject to change at time of the final release.
2021 Proposed Rule Highlights
For the MIPS Program
Limited Changes to Performance Year 2021 due to impact of COVID-19
No COVID-19 relief expected in terms of reporting duration. Full year reporting required for both 2020 and 2021.The Web Interface collection type will be grandfathered at the end of 2020.
The MIPS Value Pathways (MVP) delayed at least until 2022
For MIPS-APM Participants
A new APM Performance Pathway (APP) is proposed
Additional reporting options offered for groups participating in APMs
All the participants of MIPS-APMs (ACOs, Groups, and Individuals) will be required to report using the new APP model
Web Interface collection type will be grandfathered
APM Scoring Standard would be eliminated
Additional Scoring Flexibilities
Expanded list of reasons impacting a Quality measure during the performance period
Adding reasons to allow performance period truncation to 9 months or complete Quality measure suppression if 9 months of data is not available
Summary of Proposed Changes for 2021
To accommodate the impact the COVID-19 has had on the healthcare industry, the Centers for Medicare and Medicaid Services (CMS) is not proposing too many significant changes to the Merit-based Incentive Payment System (MIPS) for 2021. However, some key changes are as follows:
1. MIPS Value Pathways
The new method for reporting Quality Measures, MIPS Value Pathways (MVPs), which was to begin in the 2021 performance year, will be postponed. CMS will continue to work on engaging stakeholders and developing the guidelines for this new program with the potential to start in MIPS Performance Year 2022.
2. APM Performance Pathway
CMS has proposed the APM Performance Pathway (APP), which is the MVP for MIPS-APMs. This option is for MIPS APM participants only and would consist of a fixed set of measures for each performance category. The APP performance measures also satisfy the reporting requirements for the Quality Category of the Medicare Shared Savings Program.
The proposed APP Core Quality Measure set is as follows:
CAHPS for MIPS
Diabetes: Hemoglobin A1c (HbA1c) Poor Control
Preventive Care and Screening: Screening for Depression and Follow-up Plan
Controlling High Blood Pressure
(New) Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups
(New) Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs
The Promoting Interoperability (PI) category for the APP would be reported and scored at the individual or group level with the currently applicable MIPS measures. The APP track would provide 100% credit for the Improvement Activities (IA) category, and the Cost category would be weighted to zero.
3. The MIPS Performance Category Weights
In 2021, the Quality performance category weight is proposed to be reduced from 45% to 40%. The Cost category weight will then increase from 15% to 20%.
Note: The performance threshold was supposed to go to 60 points in 2021. However, CMS proposed reducing it to 50 points due to the COVID-19 crisis.
Overview of Performance Categories
1. Quality Category Proposed Changes
Quality Measure Changes: The category weight is proposed to decrease from 45% to 40% with a reduction in total number of measures available to 206.
Changes were made to 112 measures (most are Telehealth related)
14 Measures were removed
2 new claims-based measures were added
Same Year Benchmark: CMS proposes to use data from program years 2020 and 2021 for the performance period benchmarks, as opposed to historical data, for quality measure scoring. In previous years, the benchmarking baseline period was the 12-month calendar year, two years prior to the MIPS performance year. This change is to ensure accurate and reliable data and to avoid possible gaps in baseline data due to COVID-19. Therefore, in 2021, CMS proposes to use benchmarks from the 2021 performance period instead of the 2019 calendar year.
While addressing the uniqueness of COVID-19, the benchmarks based on the data from the same performance year would give rise to an issue regarding Quality Measure selection due to the uncertainty of the score based on the performance rate as the benchmarks would be assigned after the performance year is over. It’s akin to driving on a highway without any speed-limit, not knowing if you are driving slower or faster than you need to be.
The CMS Web Interface method of quality reporting for ACOs and larger registered groups, virtual groups, or other APM Entities is proposed to be grandfathered at the end of 2020. These groups would be able to report the same quality measures using the eCQM and/or MIPS-CQM equivalent of the Web Interface Quality measures.
2. Cost Category Proposed Changes
The category weight would increase from 15% to 20%. CMS proposes to update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the Total Per Capita Cost (TPCC) measure.
3. Promoting Interoperability Category Proposed Changes
The query for the Prescription Drug Monitoring Program (PDMP) stays as optional and would be increased to be worth 10 bonus points vs. 5 points in 2020.
An optional Transition of Care measure (worth 40 points) is proposed. This measure involves the connection to a Health Information Exchange (HIE) to be able to bi-directionally send and receive data electronically between providers and or points-of-service – . This new measure would be allowed to substitute for the current Referral Loop (Send/receive) Transition of Care measures.
4. Improvement Activities Category Proposed Changes
There are minimal updates that are proposed to the Improvement Activities measures. Modifications are offered to two current activities.
In 2021, 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 is still in place (also applicable for 2020).
COVID-19 Flexibility Scoring Proposed for PY 2020
CMS added and additional element to the 2021 proposed rule for the 2020 performance period only. They propose that the maximum number of bonus points available for the complex patient bonus would go from the current 5 to 10 points. This is to account for the additional complexity of treating patients during the COVID-19 public health emergency.
How Can MyMipsScore Help?
We at MyMipsScore™ will continue to monitor the actions of CMS and provide a timely update on the final rule as soon as it is published in late Fall 2020. The MyMipsScore app always incorporates the most up-to-date version of the MIPS requirements. MyMipsScore is aimed at providing MIPS program continuity to allow practices, large and small, to transition seamlessly into the next program year knowing that they will be in full compliance. We pride ourselves in assisting our customers leverage the exceptions and relaxations to maximize their MIPS composite scores to optimize their potential for incentives.