On Dec. 1, the Centers for Medicare & Medicaid Services (CMS) released the final rule for the Quality Payment Program (QPP)’s calendar year (CY) 2021 via the Medicare Physician Fee Schedule (PFS) Final Rule.
The CMS is bound by legal requirements to annually publish final rules updating Medicare payment policies in the PFS. The CMS recognizes the current limited capacity of healthcare providers to review and provide comment on extensive proposals due to the COVID-19 public health emergency. As such, the CMS has limited the required annual rulemaking to focus primarily on essential policies, including Medicare payment to providers, in addition to changes that reduce burden and may help providers in response to COVID-19.
The ACR Rheumatology Informatics System for Effectiveness (RISE) registry staff have reviewed the final rule and highlighted critical policy changes for the 2021 MIPS reporting period.
Performance Category Weights
- Quality: 40% for CY 2021 (45% for CY 2020)
- Cost: 20% for CY 2021 (15% for CY 2020)
- Promoting Interoperability: 25% (no change from CY 2020)
- Improvement Activities: 15% (no change from CY 2020)
Performance Thresholds
- Performance threshold at 60 points (45 points for CY 2020)
- Additional performance threshold for exceptional performance at 85 points (no change from CY 2020)
The CMS notes that the 2022 performance period/2024 payment year will be the final year of the additional positive adjustment for exceptional performance.
Quality Performance Category Collection Types
There is no change in policy from CY 2020. The CMS is extending the CMS Web Interface as a collection and submission type for both groups and virtual groups through the 2021 performance period. The CMS Web Interface will no longer serve as a collection/submission type beginning with the 2022 performance period.
Merit-Based Incentive Payment System (MIPS) Participation and Reporting
All MIPS-eligible clinicians, including those in a MIPS Alternative Payment Model (APM), may choose to participate in MIPS as an individual, a group, a virtual group or an APM Entity.
Clinicians in a MIPS APM will be evaluated for MIPS eligibility at the individual and group levels; the CMS will no longer evaluate Entities for the low-volume threshold. The APM Scoring Standard (reporting requirements and scoring approach for APM participants) will not be used beginning with the 2021 performance period.
Quality Measure Benchmarks
There is no change in policy from CY 2020. The CMS has determined that sufficient data were submitted for the 2019 performance period to allow it to calculate historical benchmarks for the 2021 performance period.
Improvement Activities Performance Category
- Modification of two existing improvement activities
- Continuation of the COVID-19 clinical data reporting improvement activity with modification as outlined in the September Interim Final Rule with Comment (IFC)
- Removal of one improvement activity that is obsolete
- CC_5 CMS Partner in Patients Hospital Engagement Network
Promoting Interoperability (PI) Performance Category
- The Query of Prescription Drug Monitoring Program measure will remain as an optional measure worth 10 bonus points.
- The name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information will be changed to Support Electronic Referral Loops by Receiving and Reconciling Health Information.
- A new optional Health Information Exchange (HIE) bi-directional exchange measure is added as an alternative reporting option to the two existing measures under the HIE objective.
PI Reweighting:
The following clinician types continue to be automatically excepted from having to submit data for the PI category:
- Nurse Practitioners (NPs)
- Physician Assistants (PAs)
- Certified Registered Nurse Anesthesiologists (CRNAs)
- Clinical Nurse Specialists (CNSs)
- Physical Therapists
- Occupational Therapists
- Qualified Speech-language Pathologists
- Qualified Audiologists
- Clinical Psychologists
- Registered Dieticians or Nutrition Professionals
PI CEHRT Requirements for Performance Periods in CY 2020, 2021, and 2022:
- Technology certified to the existing 2015 Edition certification criteria
- Technology certified to the 2015 Edition Cures Update certification criteria
- A combination of both to collect and report their Promoting Interoperability data and eCQMs for the Quality performance category
Cost Performance Category
- Adding telehealth services directly applicable to existing episode-based cost measures and TPCC measure
- Updated specifications available for review on the MACRA feedback page
These are key takeaways from the final rule; not all changes have been included in this overview. To learn more about the PFS Final Rule and the 2021 Quality Payment Program finalized policies, review the following resources:
- CMS Press Release – Provides additional details regarding today’s announcement
- QPP 2021 Final Rule Resources Zip File – Contains the following:
- Fact Sheet and Table – Offers an overview of the QPP final rule policies for 2021; table compares these policies to the requirements for 2020
- Frequently Asked Questions (FAQs) – Addresses the frequently asked questions for the 2021 QPP final rule policies
Questions?
Contact the Quality Payment Program at 1-866-288-8292 or [email protected].
ACR RISE registry staff are also available to assist you with questions related to reporting for MIPS. Contact the RISE registry at 404-633-3777 or [email protected].
