MIPS 2021 Final Rule: Quality and Cost Performance Measures

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The Quality Reporting Engagement Group recently reported on the Merit-based Incentive Payment System (MIPS) 2021 Final Rule and what some of the changes might mean to your practice.

For this 2021 Performance Year (PY), the threshold to avoid a penalty or negative adjustment on reimbursements from the Centers for Medicare & Medicaid Services (CMS) was raised to a minimum of 60 points. That threshold is up from three points when MIPS first started and increased from 45 points last year.

The Exceptional Performer threshold remained the same at 85 points. Meeting that threshold, practices will be eligible for a share of the $500 million ”extra” incentive provided by CMS. The Exceptional Performer bonus will be eliminated after the 2022 PY (with the reimbursements paid to your practice in 2024).

If you report nothing on MIPS for this performance year, the 9 percent negative adjustment could be a lot to your practice with CMS reimbursements in 2023.

Some of the highlights from the webinar include:

Quality
The Quality Category is 40 percent of the total composite score for the 2021 PY.

There were not a lot of proposed changes and some of the changes that were proposed were not finalized. Practices looking to find specific information on two new measures, changes to some measures and the 11 removed measures can view the webinar and the corresponding slides.

Practices must report on six measures with at least one outcome measure or one high-priority measure. Additional outcome or high-priority measures may be reported for bonus points.

Practices must have 70 percent data completeness for every measure (you are required to report on at least 70 percent of the patients who were eligible for the measure). Most EMRs will capture 100 percent of the data for eligible patients.

Cost
Weighting on the Cost Category has increased to 20 percent of the final score. CMS will raise the weighting to 30 percent by the 2022 PY.

Cost is different from the other categories of MIPS because practices will not report performance data on the measures, but rather CMS will analyze claims data at the end of the PY and provide scoring and feedback the summer following the PY on the Quality Payment Program website. If a practice is given a hardship exception, CMS will reweight the category between performance categories that could be reported on. (NOTE: Practices were allowed to request one or more performance categories to be reweighted to zero. This exception was created because of the COVID-19 Public Health Emergency (PHE). The deadline for an application by practices closed on February 1, but experts believe this hardship will be available again this coming year. Practices must apply for the exception – the hardship exception is not automatic.)

The Quality Reporting Engagement Group recommends that practices review their feedback report annually to see their cost scores and payment adjustments.

In the Cost category, there were no new measures proposed for 2021, so no new measures finalized.

Practices will not be scored on every cost measure, as a case minimum must be met for each measure. The cost measures potentially applied to your practice include Total Per Capita Cost (TPCC), Medicare Spending per Beneficiary - Clinician (MSPB – Clinician), and 18 episode-based measures which are specialty-specific (ten of which were implemented in 2020). CMS added telehealth services for reimbursement - if they were applicable directly to the measure.

The information in this article was taken from the MIPS 2021 Final Rule webinar held on Jan. 27, 2021. View the recording here.

The Quality Reporting Engagement Group has helped 99 percent of the practices they have partnered with reach the Exceptional Performer status. The team can help practices with consulting on specific measures and methods of submission or even help with handling the submission before the March deadline. The team can be reached at QREG@intrinsiq.com.

The next article will cover: Promoting Interoperability, Improvement Activities, the MIPS Value Pathways, Extreme and Uncontrollable Circumstances Exception, and Complex Patient Bonus.