MACRA Minute December 2020

Medicare Physician Fee Schedule Final Rule

On December 1st, CMS published the final policies for the 2021 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Final Rule.

2021 QPP Final Rule Highlights

  • Beginning MIPS Value Pathways (MVPs) implementation in 2022 instead of 2021
  • Performance threshold of 60 points for 2021
  • Revising performance category weights for Quality (decreases from 45% to 40%) and Cost (increases from 15% to 20%)
  • Extending the use of the CMS Web Interface as a collection and submission type for reporting MIPS quality measures in 2021 and sunsetting the option beginning with 2022
  • Sunsetting the APM Scoring Standard and allowing MIPS eligible clinicians in APMs the option to participate in MIPS and submit data at the individual, group, virtual group or APM Entity level
  • Updating third party intermediary approval criteria as well as remedial action and termination criteria

Complex Patient Bonus COVID-19 Update in 2020

The final rule also increases the complex patient bonus from a 5- to 10-point maximum for clinicians, groups, virtual groups, and APM Entities for the 2020 performance year only to offset the additional complexity of their patient population due to COVID-19.

CMS Finalizes New APM Performance Pathway for 2021

Based on stakeholder feedback, CMS will implement the APM Performance Pathway (or APP) in 2021. The APM will be:

  • Complementary to MVPs, composed of a fixed set of measures for each performance category
  • Available as an option only for MIPS eligible clinicians in MIPS APMs
  • Reported by individual eligible clinicians, groups, or APM Entities

Performance category weights under the APP will be: 50% for Quality, 30% for Promoting Interoperability, 20% for Improvement Activities, and 0% for Cost.

Final Rule Webinar:

CMS will host a webinar on Wednesday December 9, 2020 to provide an overview of the final rule for the 2021 performance year. During this webinar, CMS will answer questions from attendees at time permits.

For More Information

To learn more about the PFS Final Rule and the 2021 Quality Payment Program finalized policies, review the following resources:

  • Press Release – Provides additional details regarding today’s announcement
  • QPP 2021 Final Rule Resources Zip FileContains the following:
    • Fact Sheet and Table – Offers an overview of the QPP final rule policies for 2021; table compares these policies to the requirements for 2020
    • Frequently Asked Questions (FAQs) – Addresses the frequently asked questions for the 2021 QPP final rule policies
    • CMS MVP Submission Template – Provides instructions and a template that stakeholders should use to submit an MVP candidate for consideration.

EUC Deadline Extension

To further support clinicians during the COVID-19 public health emergency, CMS is extending the 2020 MIPS Extreme and Uncontrollable Circumstances Exception application deadline to February 1, 2021.

For the 2020 performance year, CMS will be using the Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

If you have an approved application, you can still receive scores for the Quality, Improvement Activities and Promoting Interoperability performance categories if you submit data. If the Cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted. Learn more in the 2020 Exceptions Applications Fact Sheet.

COVID-19 Impact on Cost Measures

CMS is currently monitoring the impact of the COVID-19 public health emergency (PHE) on reporting of MIPS cost measures in the 2020 MIPS performance year. Specifically, for the 18 episode-based cost measures, the Medicare Spending Per Beneficiary (MSPB) Clinician measure, and the Total Per Capita Cost (TPCC) measure, CMS is assessing the impact of lowered Medicare service utilization starting in March 2020 and continuing into the rest of the year, as related to measure reliability, beneficiary risk adjustment, and episode validity and cost comparability. Final evaluation of each measure will occur at the end of the year to determine which measures will be acceptable for 2020 reporting. Please note that MIPS program participants have the option to request reweighting of one or more MIPS performance categories due to the COVID-19 PHE, by filing an Extreme and Uncontrollable Circumstances Exception under the Quality Payment Program. More information on this option can be found here.

CMS will be hosting a virtual Town Hall meeting on January 7th to share updates on the MIPS Value Pathways (MVPs) policy considerations. The event will also be an opportunity for stakeholders to provide feedback on MVP considerations for future implementation.

Clinicians, professional organizations, third party vendors, stakeholders, and other interested parties are invited to this meeting to present their individual views on the design and implementation of MVPs. The opinions and alternatives provided during this meeting will assist CMS as they evaluate the policies on essential components of the MVP framework. 

Town Hall Details:

CMS LAN Webinar

The next LAN Webinar, Implications of the Year 5 Final Rule for Solo and Small Group Practices, will now be held January 12th and 14th.  If you already registered for this event, you will be automatically registered for the corresponding January date and will receive an email notification from Adobe Connect (you can also register for the other date if needed). Please email qppsurs@impaqint.com if you do not receive this notification by 11/26/20.

              Tuesday January 12th 10-11am CT

              Thursday January 14th 2:30-3:30pm CT

Telligen Webinars

2020 MIPS Hardship Exceptions

This webinar provides detailed information on 2020 Hardship Exceptions for both Promoting Interoperability and Extreme and Uncontrollable Circumstances. It includes details on when each application is applicable and the steps to fill out an application.

Watch the recording or download the slides here.

New Resources in the QPP Resource Library

The following resources were updated or added in November

 2020 EUC Application Resources

QPP COVID-19 Response

2020 MIPS Exception Application Fact Sheet

How to Apply for the EUC Application

2020 and 2021 Performance Years Comprehensive List of APMs

2021 QPP Final Rule Resources

2020 MIPS Scoring Guide

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