MIPS CY 2021 Rule in a Nutshell

CMS MIPS CY 2021 regulations came out last week. Here is short summary of its impact and changes.

· First, regarding the planned MIPS Value Pathway (MVP) overhaul, it was delayed and won’t be ready next year. Next year, CMS will host webinars on the matter and begin accepting MVP candidates from public. They hope to implement in 2022, but it could be pushed back even later. The MVP candidates options will have to be presented in rule making for public comment before being finalized.

· As a refresher, MVP will be a collection of streamlined measures and activities targeted to a given physician’s specialty. This should result in reducing reporting burden and make it easier to compare results for the same types of physicians compared to the existing MIPS framework.

· MVP is going to look similar to the new APM Performance Pathway (APP) which is coming in CY 2021. APP is for MIPS APMs clinicians. CMS seems to be trying to merge or at least align MIPS and APM programs. MIPS APM reporting itself is more aligned with MIPS in CY 2021.

· For main MIPS program itself in CY 2021, it will look quite similar to CY 2020. Changes are minor. More things are the same than different.

· MIPS CY 2021 performance category weight is Quality=40% (-5% from this year), Cost=20% (+5% from this year), PI=25%, IA=25%.

· Quality category is largely the same with its normal yearly updates. Some new measures, changes to many existing measures, and removal of 11 CQM (none are eCQMs). For QCDRs and Qualified Registries and 3rd party health IT intermediaries, more details on data validation audits and compliance since that has been a point of concern to CMS.

· For the Promoting Interoperability Category, it is largely the same with one notable addition. A new, alternative HIE bi-directional exchange measure can be used in place of the two Referral Loop measures if providers enable bi-directional exchange with HIE for all patient records in their EHR.

· The HIE Bi-Directional Exchange measure is yes/no attestation. Other measures are the same, including the bonus Query PDMP measure (yes/no attestation) which provides 10 bonus points.

· For Cost and Improvement Activity categories, a few small changes but largely the same.

· MIPS scoring is largely the same except the performance threshold is now at 60 points (which is the value CMS had previously indicated they move to). Exceptional performance threshold remains at 85 points. Maximum negative payment adjustment is still -9%.

· Another change is offering 10 bonus points (up from 5) for treating complex patient populations which includes COVID-19.

· Finally, like this year, COVID-19 PHE can be used for CY2021 hardship exception consideration.