It’s a new year, and that means a new set of policies for the Merit-Based Incentive Payment System (MIPS). Many of the reporting requirements remain the same as last year, but there are a few key changes. The chart below outlines all the major changes taking place in 2021, but here are some of the highlights:
- The potential penalty for nonparticipation remains the same at 9%. Penalties or bonuses from 2021 MIPS performance will impact payment in 2023.
- The low-volume threshold for MIPS remains the same: you are exempt if your annual Medicare Part B allowed charges are equal to or less than $90,000, OR you furnish covered professional services to 200 or fewer Medicare Part B patients, OR you provide 200 or fewer covered professional services to Part B patients.
- Allergists will have to do more to avoid a penalty; you now need 60 MIPS points (up from 45 in 2020) to avoid a penalty.
- The exceptional performance bonus threshold remains the same at 85 points. Practices receiving 85 or more points will receive a proportionate share of the annual $500 million bonus.
- Four new quality measures were added to the A/I specialty measure set. Two are related to sinusitis, and two are related to asthma.
- In recognition of the continued hardships related to COVID-19 facing practices, the COVID-19 Extreme and Uncontrollable Circumstances Exception will remain an option in 2021. Practices can request to re-weight any or all MIPS performance categories under this exception by submitting an application stating their practice has been significantly impacted by the COVID-19 public health emergency. Practices that receive a hardship exemption in all four categories will avoid a MIPS penalty. However, if a clinician or group submits data for the 2021 performance period, the data submission will override the exception, and the clinician or group will be scored on the data submitted. The Centers for Medicare and Medicaid Services (CMS) is expected to release the application, along with additional resources and further clarification, in Spring 2021.
If you haven’t done so already, check your MIPS participation status for 2021. If you need to participate, get started now. CMS has improved its MIPS resources over the past few years. The agency offers several helpful resources in the QPP Resource Library that provide details about the program, which we’ve outlined below.
The potential penalty for nonparticipation is significant, but with careful planning, you can avoid it!
MIPS Policies for 2020 vs 2021
|Policy||2020 Performance Year|
(2022 Payment Year)
|2021 Performance Year|
(2023 Payment Year)
|COVID-19 Extreme and Uncontrollable Circumstances Exception||Can request to re-weight any or all MIPS performance categories; must submit an application listing “COVID-19” as the cause.||No change|
|Penalty or bonus||+/- 9%||No change|
|Reporting Period*||Quality and cost: full calendar year|
PI and IA: any 90 consecutive days
|Category Weights*||Quality 45%|
|Low Volume Threshold||Bill >$90,000 Medicare Part B charges|
See >200 Part B patients
Provide >200 covered services to Part B patients
|CEHRT Edition||Must use technology meeting the existing 2015 Edition certification criteria OR technology certified to the 2015 Edition Cures Update certification criteria OR a combination of both to report data for the PI performance category, and to report eCQMs for the Quality performance category||No change|
|Small Practice Bonus|
(15 or Fewer Eligible Clinicians)
|6 points added to Quality for clinicians in a small practice who submit at least 1 measure; not added to clinicians or groups who are scored under facility-based scoring.||No change|
|Complex Patient Bonus||Up to 10 points to total score (complex patient bonus doubled due to complexity associated with COVID-19)||Up to 5 points to total score|
|Other Quality Category Bonuses||Improvement bonus (up to 10 points) for improvement in Quality performance category from prior year|
End-to-end reporting using CEHRT
Submit 2 or more outcome or high priority quality measures (Not available for the first, required outcome or high priority quality measure. Not available for measures required by the CMS Web interface.)
|Quality Data Submission Options||Can submit quality data via multiple submission methods (EHR, registry, etc.)||No change|
|Quality Reporting via Claims||Available for clinicians in small practices (<= 15 eligible clinicians)||No change|
|Cost category||N/A||Cost measure will include applicable telehealth services|
|PI Hardship Exemption*||Includes MIPS eligible clinicians in a small practice (15 or fewer eligible clinicians); must submit a hardship application||No change|
|Quality Data Completeness Threshold||70% of patients who qualify for each measure||No change|
|IA Group Reporting Participation Threshold*||50% of clinicians in the practice must participate and report the same IA||No change|
|Minimum Points to Avoid a Penalty||45 points||60 points|
|Exceptional Performance Threshold to Receive an Extra Bonus||85 points||No change|
|MIPS Value Pathways||N/A||Delayed until 2022; will be a voluntary reporting option|
|*PI = Promoting Interoperability, IA = Improvement Activities|
CMS MIPS resources in the QPP Resource Library
The 2021 MIPS Quick Start Guides are a series of guides that explain how clinicians can start participating in MIPS during the 2021 performance period. These downloadable resources include:
- MIPS Overview
- Eligibility and Participation
- Part B Claims Reporting
- Quality Performance Category
- Promoting Interoperability Performance Category
- Improvement Activities Performance Category
- Cost Performance Category
More resources are:
- 2021 MIPS Data Validation Criteria – Includes the criteria used to audit and validate data submitted in the quality and improvement activities categories.
- 2021 Quality Benchmarks – Lists and explains 2021 benchmarks used to assess performance in the Quality performance category.
- 2021 MIPS Quality Measures List – Lists in detail the 2021 Quality Measures, including the 14 measures in the allergy/immunology specialty measures set.
- 2021 Improvement Activities Inventory – Lists the 2021 improvement activities and includes descriptions for each.
- 2021 Qualified Registries Qualified Posting – Lists the vendors approved by CMS to be Qualified Registries for the 2021 MIPS performance period.
- 2021 QCDRs Qualified Posting – Lists the vendors approved by CMS to be Qualified Clinical Data Registries (QCDRs) for the 2021 MIPS performance period.