2021 QPP Updates

CMS continues to refine policies in the APM track. Overall, the changes for 2021 are relatively minor adjustments to address highly specific issues.

To prevent potential dilution of the QP threshold score, CMS will remove patients who are not allowed to be attributed to the APM entity. The rule also created a targeted review process through which clinicians can request that CMS address errors in QP determination. In situations when clinicians who earn QP status later change TINs, the incentive payment will be paid out according to a hierarchy that identifies the appropriate recipient.

QP thresholds remain the same after Congressional intervention

According to the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, the QP thresholds were slated to increase substantially in 2021. This increase would have made it harder for APM participants to qualify for the APM track and receive the 5% lump-sum bonus.

At the end of 2020, Congress intervened to delay the scheduled increase. The Consolidated Appropriations Act of 2021 froze the QP thresholds at their performance year 2020 levels for performance years 2021 and 2022. Because of this, organizations that previously met the threshold and qualified for the APM track will likely qualify again in 2021.

QP Thresholds 2020-2022

50% Payment amount

35% Patient count

CMS intends to establish MVPs as a new MIPS reporting framework, but the rule delayed implementation until 2022. MVPs are a reporting framework that group related quality, cost, and improvement activities measures for MIPS by condition or specialty. CMS will continue to allow traditional MIPS reporting as it begins to introduce MVPs as a new reporting framework.

The rule didn’t include exact details of which MVPs will be available and how they will work. But CMS did finalize several guiding principles to steer future MVP development. MVPs should:

• Include connected and complementary sets of measures and activities
• Generate comparative performance data
• Use the Meaningful Measures approach and include patient voice
• Reduce barriers to APM participation by including existing APM measures where feasible and linking cost and quality measurement
• Support the transition to digital quality measures

CMS is seeking stakeholder feedback as it finalizes implementation details. There will be several opportunities for stakeholders to participate in the MVP development process across 2021, and as CMS continues to roll out MVP options in future years.

The APP is a new, optional reporting framework for MIPS APM participants that replaces the APM Scoring Standard. Clinicians can report the APP at the individual, group, or APM entity level. The performance category weights are Quality: 50%, Improvement Activities: 20%, and Promoting Interoperability: 30%. The APP does not score clinicians on cost.

The APP Core Quality Measure Set includes six total measures. Three measures must be reported through either Electronic Clinical Quality Measure (eCQM) or MIPS Clinical Quality Measure (CQM) submission, which includes all-payer data. The remaining measures are scored by CMS based on Medicare claims or through data submitted through a survey vendor.

CMS Web Interface no longer available starting 2022

For 2021 only, clinicians can choose to report the ten CMS Web Interface measures. This allows some flexibility and time, if needed, to implement the three measures in the APP Core Quality Measure Set highlighted in red below.

The rule finalized a few changes to the traditional MIPS categories, in keeping with typical updates expected in annual rulemaking. The table below outlines the most important changes in each category.

New HIE measure may boost PI performance, reduce reporting burden

The optional new HIE Bi-Directional Exchange measure is an alternative to the two existing HIE send-and-receive/reconcile measures. Clinicians need not submit performance data for the bi-directional measure. Reporting a “yes” earns 40 points. This could be an attractive option for clinicians who engage in bidirectional exchange through an HIE. See how it fits into existing PI requirements on page 10 of the PDF or by downloading the 2021 MIPS PI measure guide.

1. TPCC: Total Per Capita Cost.
2. MSPB-C: Medicare Spending Per Beneficiary Clinician.

MIPS Performance Threshold

CMS did not make significant changes to its overall scoring methodology for MIPS. But by design, MIPS requirements are intended to get harder each year.

The performance threshold (PT), or number of points clinicians must achieve to avoid a penalty, is set at 60 points for the 2021 performance year. This is an increase from 45 points in 2020. Exceptional performance, or the points needed to qualify for additional incentives, remains at 85 points.

Maximum MIPS incentives may remain low

MIPS is a budget-neutral program, where penalties collected are used to fund positive adjustments. Generally, increasing the PT would mean more penalties. However, due to Covid-19, CMS extended its Extreme and Uncontrollable Circumstances policy to help impacted clinicians avoid penalties.

That means high-performing MIPS clinicians can expect positive adjustments to remain low. It’s likely that only clinicians who achieve exceptional performance will receive incentives, funded by an additional $500 million set aside by law to reward the highest performers.

The rule acknowledges that the Covid-19 pandemic continues to impact clinicians due to extreme and uncontrollable circumstances. CMS has used the Extreme and Uncontrollable Circumstances (EUC) Exception application as the primary way to provide clinicians relief from potential penalties during the Covid19 public health emergency (PHE). The EUC policy for Covid-19 was extended through the 2021 performance year.

Individuals, groups, and virtual groups

In 2021, individuals and groups can apply to reweight one or more performance categories, as was the case in 2020. This applies to clinicians who are prevented from collecting or reporting MIPS data due to Covid-19, or whose cost performance has been impacted. Subsequent MIPS reporting overrides any reweighting on a per-category basis, with the exception of the cost category, since clinicians don’t report cost data to CMS.

APM Entities

Beginning in 2021, APM entities are allowed to apply for reweighting of all categories. APM entities cannot pick and choose which categories to reweight, and cannot override their reweighting by submitting data later on. If an APM entity is approved to reweight all categories, it would receive a MIPS final score equal to the performance threshold, resulting in a neutral adjustment.

What you should do in response

Download our checklist to guide your 2021 QPP strategy. These are the main areas on which to focus in response to this year’s final rule, based on whether you participate in an Advanced APM, MIPS APM, or traditional MIPS.

Get the checklist