Quality Payment Program Provisions in Fee Schedule Proposal Set Stage for 2021 and Postpandemic Landscape

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The Centers for Medicare & Medicaid Services (CMS) released its 2021 Medicare Physician Fee Schedule (MPFS) proposed rule, which includes updates to the Quality Payment Program (QPP). For the QPP 2021 performance period, CMS proposes the following Merit-based Incentive Payment System (MIPS) performance threshold and category weights:

  • Performance threshold = 50 points (10-point decrease from 2020)
  • Quality performance category = 40% (5% decrease from 2020)
  • Cost performance category = 20% (5% increase from 2020)
  • Promoting interoperability performance category = 25% (no change from 2020)
  • Improvement activities performance category = 15% (no change from 2020).

CMS previously determined that MIPS Value Pathways (MVPs) would begin with the 2021 performance period. MVPs would connect activities and measures from MIPS performance categories that are relevant to a specific patient population, medical specialty, or medical condition to reduce the burden of participating in MIPS and allow CMS to collect more meaningful performance data. However, due to stakeholder concerns about the implementation timeline—and with clinicians working hard to address the spread of COVID-19 within their practices and communities—CMS will not introduce MVPs in 2021.

The agency is proposing a new Alternative Payment Model (APM) Performance Pathway (APP) reporting option for 2021 that aligns with the MVP framework. As part of the APP introduction, CMS will sunset the CMS Web Interface as a collection type beginning with the 2021 performance period.

CMS also proposes changing the maximum number of points available for the complex patient bonus to account for the additional complexity of treating patients during the COVID-19 pandemic. As proposed, clinicians, groups, virtual groups, and APM entities could earn up to 10 bonus points toward their final MIPS score for the 2020 performance year. This increase would be available for the 2020 performance period only.

CMS also proposes allowing APM entities to apply to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the COVID-19 pandemic. This policy would begin with the 2020 performance period.

A more complete analysis is available on ASCO in Action.  

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