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As clinicians across the country continue to respond to COVID-19, the Centers for Medicare and Medicaid Services’ (CMS) proposed 2021 Medicare Physician Fee Schedule included a limited number of significant changes to the Quality Payment Program (QPP) in 2021. Highlights of the 2021 QPP include:
- Delayed implementation timeline for the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) until the 2022 performance period. CMS is proposing additions to the framework’s 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.
- Introduction of the Alternative Payment Model (APM) Performance Pathway (APP) to align with the MVP framework. As part of APP implementation, the CMS Web Interface would be sunset as a collection type beginning in the 2021 performance period.
- An increase in the performance threshold to be 50 points in 2021 from 45 points in 2020 and an increase in exceptional performance to be 85 points in 2021 from 80 points in 2020.
- A revision of the performance category weights for Quality to 40 percent in 2021, a five percent decrease from 2020. An increase in Cost performance category for Cost to 20 percent in 2021, a five percent increase from 2020. Additionally, Cost and Quality performance categories would be equally weighted at 30 percent beginning in the 2022 performance period. Existing measure specifications in the Cost category would be updated to include telehealth services that are directly applicable to existing episode-based cost measures.
- Promoting Interoperability and Improvement Activities would be maintained at 25 percent and 15 percent, respectively.
- A 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.
- CMS is soliciting comments on a lower performance threshold of 50 points, previously 60 points in CY 2020.
- Updates to the Medicare Shared Savings Program (Shared Savings Program) quality performance standard and quality reporting requirements for performance years beginning on Jan. 1, 2021 to align with Meaningful Measures, reduce reporting burden and focus on patient outcomes.
- A proposal to reduce the total number of measures in the ACO quality measure set from 23 to 6 measures, and the number on which ACOs are required to actively report would be reduced from 10 to 3.
- Expansion of the use of the APM Entity submitter type to allow the use of all MIPS submission mechanisms.
- A proposal to end the APM Scoring Standard beginning with the 2021 performance period. CMS is also proposing to add the APM Entity as a submitter type which may report to MIPS on behalf of associated MIPS eligible clinicians.
- CMS is proposing that Medicare patients who have been prospectively attributed to an APM Entity during a QP Performance Period not be included as attribution-eligible Medicare patients for any APM Entity that is participating in an Advanced APM that does not allow such prospectively attributed Medicare patients to be attributed again.
- A proposal to use the performance period, not historical, benchmarks to score quality measures for 2021; updating the scoring policy for topped-out measures, so that the 7 measure achievement point cap will be applied only if the measure is identified as topped out based on the established benchmarks for both the 2020 and 2021 performance periods.
- The rule addresses changes to 112 existing MIPS quality measures; removes 14 quality measures; and proposes 206 quality measures starting in 2021, including two new administrative claims-based measures, one of which has a three-year measurement period.
- Updates to requirements for Qualified Clinical Data Registry (QCDR) measures and the services that third-party intermediaries must provide (beginning with the 2021 performance period). Additionally, QCDR measures would be required to be fully tested at the clinician level in order to be considered for inclusion in an MVP, beginning with the 2022 performance period.
Additional Resources:
CMS Releases Proposed 2021 Medicare Physician Fee Schedule and Hospital Outpatient Rules
Proposed 2021 Medicare Physician Fee Schedule Telehealth Highlights
