Introduction to MIPS 2021 Proposed Rule

Overview of CMS Announcement

The Centers for Medicare and Medicaid Services (CMS) has released the proposed rule for the Quality Payment Program (QPP) Merit-based Incentive Payment System (MIPS) for 2021 through the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM). This article examines the anticipated changes for MIPS in 2021, emphasizing that these changes are currently proposals and not yet finalized.

Importance of MIPS Reporting

Every year, CMS introduces various guidelines to assist physicians with their payment structures. The manner in which MIPS consultants manage administrative data for reporting significantly impacts revenue cycles. Correctly reporting MIPS data is essential for clinicians linked to Medicare, as it contributes to revenue growth year after year.

Impact of COVID-19 on MIPS 2021

Challenges Ahead for QPP MIPS

The 2021 QPP MIPS may present several challenges, particularly related to delays, similar to those experienced during the 2020 performance period. The pandemic has forced a shift in focus from the volume of patients to the quality of care provided. Consequently, it seems reasonable to expect delays in the implementation of MIPS Value Pathways (MVPs) for 2021.

Response to the Pandemic

In response to COVID-19, CMS is considering additional reporting flexibilities. Notably, MIPS incentives are anticipated to be more substantial compared to previous years, with P3Care potentially offering clients up to a +5% positive payment adjustment.

MIPS Value Pathways (MVPs)

Proposed Changes for MVPs

The proposed rule indicates that MIPS Value Pathways (MVPs) will be postponed until 2022. However, they will remain available as optional reporting methods for eligible clinicians alongside other MIPS data submission choices.

APM Performance Pathways

Participants in MIPS Alternative Payment Models (APMs) may report using APM Performance Pathways (APPs), which function similarly to MVPs. CMS is also considering discontinuing the current APM score standards in 2021.

Eligibility for APPs

Only specific groups can utilize APPs, including:
– Individual eligible clinicians
– Groups (Tax Identification Number – TIN)
– APM entities
– MIPS APM participants

ACOs participating in the Medicare Shared Savings Program must report quality performance using the APP.

Performance Category Scoring for APPs

The scoring for APPs is structured as follows:
– Quality Category: 50% weight, featuring six measures focused on population health.
– Improvement Activities (IA) Category: 20% weight, with scores automatically assigned based on MIPS APM requirements.
– Promoting Interoperability (PI) Category: 30% weight, required for all QPP MIPS submissions, reported and scored at the individual or group level.
– Cost Category: 0% weight, with automatic inclusion in the Medicare Shared Savings Program (MSSP) quality scoring.

QPP MIPS Program Updates

Data Submission Options for MIPS 2021

In 2021, multiple data submission options will be available for MIPS consulting services to aid eligible clinicians, including:
– Virtual Groups
– Solo Eligible Clinicians
– Groups
– APM Entities

The virtual group will hold the highest hierarchical priority when CMS receives multiple scores.

APM Participation and Reporting

Eligible clinicians participating in APMs can report QPP MIPS data for both Quality and Improvement Activities performance categories. They can choose and report MIPS quality measures similarly to eligible clinicians reporting for QPP MIPS. Typically, the APM Entity group calculates performance for Improvement Activities.

Proposed Changes from CMS

Web Interface Reporting Mechanism

CMS aims to facilitate MIPS data submission for groups and virtual groups by proposing the sunset of the CMS Web Interface as a reporting method. This change targets larger group participants in QPP MIPS 2021, APMs, and MSSP, driven by a reported 45% reduction in its usage.

Changes in APM Reporting

Many APM participants may opt for APP for quality reporting. CMS proposes establishing six quality measures for APM reporting, including:
– Controlling High Blood Pressure
– Diabetes: Hemoglobin A1c Poor Control
– Preventive Care and Screening: Screening for Depression and Follow-up Plan
– Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs
– Hospital-Wide, 30-day, All-Cause Unplanned Readmission Rate for MIPS Eligible Clinician Groups

These measures aim to alleviate administrative burdens and enhance focus on quality patient outcomes.

ACO Reporting Adjustments

The proposed rule for QPP MIPS 2021 suggests several changes for Shared Savings ACOs, including multiple data submission methods. This adjustment allows participants to submit data individually rather than solely through the ACO entity, potentially improving the efficiency of the reporting process.

Adapting to Changes in MIPS Data Submission

Consulting Services for Compliance

It is important to note that the proposed rule may differ from the final rule. Even with changes in reporting requirements, they are likely to remain somewhat consistent. Engaging professional MIPS consulting services is advisable to navigate these changes effectively.

Conclusion

The QPP MIPS 2021 program introduces notable differences in quality reporting compared to previous years, especially in light of the ongoing pandemic. The emphasis on patient empowerment through value-based outcomes has intensified. While adapting to new reporting requirements may take time, collaborating with experienced MIPS consultants can streamline the process.

Medical practices should align their strategic goals with these efforts, using the beginning of the performance year to experiment with various measures. This represents an opportunity to recoup revenue lost during the pandemic by effectively implementing QPP MIPS 2021 performance strategies.