The final 2021 Medicare Physician Fee Schedule released by the Centers for Medicare and Medicaid Services on Dec. 1 included a number of changes to the Quality Payment Program (QPP) to account for the ongoing COVID-19 public health emergency (PHE). Highlights include:

• Delayed implementation timeline for the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) until the 2022 performance period. CMS finalized the set of guiding principles and development criteria to support stakeholder engagement in co-developing MVPs and establishing a clear path for MVP candidates to be recommended through future rulemaking.
• A finalized new reporting framework, the Alternative Payment Model (APM) Performance Pathway (APP), to align with the MVP framework and begin in 2021. To account for the challenges faced in transitioning to alternative collection type, CMS is sunsetting the CMS Web Interface as a collection and submission type, but will extend the availability of the CMS Web Interface as a collection and submission type for one year in the 2021 performance period.
• Finalize individual MIPS and traditional MIPS reporting performance category weights for Quality to 40% in 2021, a 5% decrease from 2020. An increase in Cost performance category for Cost to 20% in 2021, a 5% increase from 2020. Additionally, Cost and Quality performance categories must be equally weighted at 30% beginning in the 2022 performance period.
• Maintained the Promoting Interoperability and Improvement Activities performance categories at 25% and 15%, respectively.
• Finalized the proposal for the 2020 performance period only to double the complex patient bonus. Clinicians, groups, virtual groups and APM entities would be able to earn up to 10 bonus points (instead of five bonus points) to account for the additional complexity of treating their patient population due to COVID-19.
• In response to the COVID-19 PHE, the performance threshold for the 2021 performance period will remain at 60 points as finalized.
• Beginning with QPP Year 6 (2022 performance period), the performance threshold must be set at the mean or median of the final scores for all MIPS eligible clinicians for a prior period, and the Quality and Cost performance categories must be equally weighted at 30% each.
• For the 2020 performance year, all ACOs are considered to be affected by the PHE, and the Shared Savings Program extreme and uncontrollable circumstances policy applies. For the 2020 performance year only, CMS finalized the proposal to waive the requirement for ACOs to field a CAHPS for ACOs survey. ACOs will receive automatic full credit for the patient experience of care measures.
• Updates to the Medicare Shared Savings Program (Shared Savings Program) quality reporting requirements are as follows:
• For the 2021 performance year, ACOs will be required to actively report either the 10 measures under the CMS Web Interface or the three eCQM/MIPS CQM measures. In addition, ACOs will be required to field the CAHPS for MIPS Survey, and CMS will calculate two measures using administrative claims data. Based on the ACO's chosen reporting option, either six or 10 measures will be included in the calculation of the ACO's MIPS Quality performance category score.
• For the 2022 performance year and subsequent performance years, ACOs will be required to actively report quality data on the three eCQM/MIPS CQM measures via the APP. In addition, ACOs will be required to field the CAHPS for MIPS survey, and CMS will calculate two measures using administrative claims data. All six measures will be included in the calculation of the ACO's MIPS Quality performance category score.

• Expanded the use of the APM Entity submitter type to allow the use of all MIPS submission mechanisms.
• Finalized the proposal to sunset the APM Scoring Standard beginning with the 2021 performance period. The APM entity is added as a submitter type which may report to MIPS on behalf of associated MIPS eligible clinicians.
• CMS did not finalize the use of the performance period benchmarks exclusively to score quality measures for the 2021 performance period, or the related policy to allow 2021 performance periods benchmarks to inform whether a topped out measure is capped at seven points.
• The rule addresses changes to 113 existing MIPS quality measures; removes 11 quality measures; and adds two new administrative claims-based measures.
• Allows Qualified Clinical Data Registry (QCDR), Qualified Registries, and health IT vendors to support MVPs, beginning in the 2022 performance period; and the APP, beginning with the 2021 performance period.
• QCDR measure data collection and testing requirements would be delayed until the 2022 performance period, as outlined in the March IFC.

ACC staff are reviewing the proposed rules to identify additional topics of interest to members. More information will be forthcoming in the Advocate newsletter and on ACC.org in the coming weeks. A fee schedule fact sheet is available here, press release here, and a QPP fact sheet is available here.

Keywords: ACC Advocacy, Medicare, Centers for Medicare and Medicaid Services, U.S., Medicaid, Quality Indicators, Health Care, COVID-19, severe acute respiratory syndrome coronavirus 2, Fee Schedules, Mandatory Reporting, Registries

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