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Policy Primer

2021 QPP Updates

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On December 28, 2020, the Centers for Medicare and Medicaid Services (CMS) published the 2021 Medicare Physician Fee Schedule (MPFS) final rule, which includes updates to Medicare Part B reimbursement rates. The MPFS rule also updates requirements for the Medicare Quality Payment Program, including the MIPS and APM tracks.


What is the Quality Payment Program?

The Quality Payment Program (QPP) is a CMS pay-forperformance program that affects Medicare Part B reimbursement. There are two payment tracks under the QPP that can clinicians participate in:

  • Advanced Alternative Payment Models (APM)
  • Merit-based Incentive Payment System (MIPS)


Key changes at a glance

The 2021 final rule includes several changes for eligible clinicians participating in the Quality Payment Program (QPP). CMS offers short-term flexibility in response to the Covid-19 public health emergency while pushing forward several long-term goals of the QPP. There were minor updates to the APM track policies. The introduction of the APM Performance Pathway (APP) reporting framework in the MIPS track signals CMS’s intention to reduce the reporting burden and make quality reporting more meaningful to providers.

See where the key changes fall within the tracks of the Quality Payment Program below.

APM track

  • Updated Qualifying APM Participant (QP) threshold score calculation to remove patients who cannot be attributed to the APM entity
  • Created a targeted review process to fix errors in QP determination
  • Established a hierarchy to identify appropriate incentive payout recipient when clinicians change Tax Identification Numbers (TINs)
  • QP thresholds were slated to rise in 2021, but the Consolidated Appropriations Act of 2021 delayed the increase until 2023

MIPS track

  • MIPS Value Pathways (MVPs) implementation delayed until 2022
  • 2021 MIPS Performance Threshold set at 60 points, with exceptional performance set at 85 points
  • Optional, alternative Bi-Directional HIE measure introduced in the Promoting Interoperability performance category
  • APP created as an optional reporting framework for MIPS APM participants that replaces the APM Scoring Standard
  • CMS Web Interface will no longer be available for Quality measures submission beginning in 2022
Five highlights of the new rule
  • 1. Minor APM track updates
  • 2. MVPs delayed to 2022
  • 3. APP available in MIPS
  • 4. Few updates to MIPS categories
  • 5. Covid-19 relief extended through 2021

What this means for the program

CMS is balancing long-term policy goals while remaining responsive to the unprecedented challenges providers are facing with the Covid-19 public health emergency.

The rule included minimal program updates compared to pre-Covid rulemaking. Several planned changes were postponed, such as implementing MVPs and sunsetting the CMS Web Interface. CMS also continues to lean on the EUC exception policy to help impacted clinicians avoid negative payment adjustments.

At the same time, CMS has pushed forward on certain MIPS updates in support of how the program will evolve:

  • The performance threshold continues to increase year over year. This has created a situation in which CMS will use the historical mean or median score to establish the performance threshold beginning in 2022.
  • Performance category weights continue to move toward their mandated levels in 2022. By then, both quality and cost categories are required to be weighted 30%.
  • While the MVP framework was delayed until 2022, the introduction of the APP serves an indicator for how CMS envisions clinicians will use MVPs.
  • Medicare Shared Savings Program policies will evolve in alignment with MIPS changes, resulting in a significant impact on ACOs.

Looking ahead, we can expect that QPP updates will reflect CMS’s goal to move clinicians toward value-based care models.

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