The Centers for Medicare and Medicaid Services (CMS) is proposing a number of changes to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS) for reporting year 2021. Also proposed are some adjustments to 2020 reporting to address circumstances related to the COVID-19 pandemic. These changes, announced as part of the 2021 Proposed Physician Fee Schedule Rule, would take effect January 1, 2021 and would impact performance bonuses in 2023.
As a refresher: MIPS comprises four performance categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. A provider’s score for each of these categories determines one’s total MIPS score and corresponding payment adjustment. For 2021, clinicians that participate in Advanced Alternative Payment Models (APMs) can be exempt from MIPS if they receive at least 75% of their Medicare revenue through the Advanced APM or see at least 50% of their patients through the advanced APM. This is an increase from last year and is required by law.
Unless an allergy practice is exempt from MIPS, failure to participate in MIPS will result in negative Medicare adjustments of up to 9% going forward. Exemption examples include low volume or because the practice participates in an APM.
Proposed Reporting Year 2020 Adjustments
For reporting year 2020 (bonus year 2022), CMS proposes to double the complex patient bonus from five points to up to ten points to account for the additional complexity of providing care during the pandemic. Beginning in 2020, and continuing thereafter, it will also allow APM entities to apply to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances.
As a reminder, physicians have the option to opt out completely or partially from 2020 MIPS reporting due to the COVID-19 public health emergency. Read our recent Advocacy Insider article for details.
Proposed Reporting Year 2021 Adjustments
As part of its plan to slowly increase the weight assigned to the cost category, CMS proposes the following:
- The Cost Category would increase to 20% from 15% in 2020.
- The Quality Category would decrease to 40% from 45% in 2020.
- The Improvement Activities and Promoting Interoperability Categories would stay the same as 2020 at 15% and 25%, respectively.
MIPS-eligible clinicians would need to have a MIPS score of at least 50 points in 2021 to avoid a penalty of up to 9% in 2023; 85 points is required to receive an exceptional performance bonus.CMS also projects that the maximum MIPS bonus will be between 6.9% and 7.4% in 2023 (based on 2021 data) for those with exceptional scores. This compares with 2020 highest adjustments (based on 2018 performance) of only 1.68%. The low adjustments are largely due to the requirement that CMS implements MIPS payment adjustments in a budget-neutral manner, and because successful performance rates are high, with very few downward adjustments to offset MIPS bonuses, there are limited funds for bonuses.
COVID-19 Adjustment for Performance Benchmarks
In April of this year, CMS announced that, as a result of the pandemic, it would provide for a neutral payment adjustment for clinicians who did not submit any MIPS data for 2019 by the extended deadline of April 30, 2020. Because this could result in inadequate data for 2019 to set performance benchmarks for 2021, CMS is proposing that 2021 performance benchmarks would be based on actual data submitted during 2021 (instead of 2019). This would mean that clinicians would not know the benchmarks for 2021 in advance, including which measures are topped out.
MIPS Value Pathways (MVPs)
CMS has been developing a new structure for MIPS reporting that is focused on certain specialties, treatments, and other priorities. The MVP framework was scheduled to begin in 2021, but CMS proposes to delay it until 2022. However, the MVP pathways and measures under development do not yet include allergy.
Advanced Payment Models (APMs)
CMS estimates that there will be approximately 252,000 clinicians who are qualified participants in advanced APMs in 2021 and who are therefore exempt from MIPS reporting. This number is less than in 2019 and 2020.
MIPS Reports for 2019
If you participated in MIPS in 2019, your 2019 MIPS performance feedback, 2019 final scores, and 2021 payment adjustments are now available on the QPP website. Clinicians or group practices may request a targeted review if they find an error with their 2021 MIPS payment adjustment.