On Monday, CMS released the CY 2021 Medicare Physician Fee Schedule (PFS) Proposed Rule—which contains updates to the Quality Payment Program (QPP).
CMS is accepting public comments on the proposed rule until October 5th, 2020.
How CMS wants to update the QPP
This year, we expected to see CMS propose few QPP updates, and ease up on several policies in response to Covid-19—like the timeline of the MIPS Value Pathways rollout. What we didn't expect was the changes to ACO quality reporting requirements and elimination of the MIPS APM scoring standard as early as 2021.
Read on for the proposals you need to know and our take.
- MIPS Value Pathways delayed until at least 2022
Last year, CMS finalized its intent to overhaul MIPS through implementing MIPS Value Pathways (MVPs), which will group measures from the quality, cost, and improvement activity categories based on medical condition or specialty. MVPs were slated to take effect in 2021, but few details surrounding their implementation had been finalized.
As a relief for many providers, CMS proposed to delay the implementation of MVPS until 2022 at the earliest. In the meantime, CMS proposed guiding principles and criteria for how they will work with stakeholders to create new MVP options.
- CMS proposes key changes to ACO reporting and scoring policies
For ACOs, there's a lot to unpack. CMS proposed to sunset the CMS Web Interface, beginning in 2021. Currently, ACOs use the CMS Web Interface to report quality measures under both their ACO contract and for MIPS. This proposal is consistent with overall efforts to reduce the number of measures reported by ACOs and keep MIPS aligned with MSSP reporting requirements.
CMS also wants to eliminate the MIPS APM scoring standard beginning in 2021. It would be replaced by the APM Performance Pathway (APP). The APP takes a similar approach to MVPs in that it aims to include a fixed set of measures for each performance category. Similar to MIPS APM scoring standard, cost will be weighted at 0% in the APP.
- Response to Covid-19 drives many expected updates
CMS includes several policies to help clinicians avoid penalties. For the 2020 performance period only, the total possible points available through the complex patient bonus points will increase to 10 points from 5 points. The proposal also addresses APM entities that experience extreme and uncontrollable circumstances—they can submit an application to reweight MIPS performance categories beginning with the 2020 performance period.
For 2021, the proposal sets the performance threshold to avoid the MIPS penalty at 50 points, a 5-point increase rather than a planned 15-point increase to 60 points.
Other noteworthy proposals
- For APM participants, CMS proposed several minor changes to QP threshold calculation and the hierarchy for distribution of APM incentives. Remember, QP thresholds are also required by law to increase in 2021.
- For MIPS participants, key proposals and category weights for 2021 are:
- Quality 40% (5% decrease): CMS Web Interface submission method no longer available;
- Cost 20% (5% increase): Update measure specifications to include telehealth services for existing episode-based cost measures and TPCC measures;
- Improvement Activities 15%: Minimal changes focus on the process for nominating new activities; and
- Promoting Interoperability 25%: New optional HIE bidirectional exchange measure.
Our takeaways for providers
- Expect low MIPS bonuses due to Covid-related policies A few weeks ago, CMS announced it would make the extreme and uncontrollable circumstances policy available to MIPS participants who wanted to reweight one or more MIPS categories in 2020 due to Covid-19. In the proposal, CMS extends this policy to ACO participants. While necessary to help providers avoid penalties in these unprecedented times, those poised to do well in MIPS should expect small bonuses the next several years. That's because MIPS is budget neutral, so it uses penalties to fund incentives.
- MVPs delayed, but not forgotten While the start date is postponed, the proposal outlines how CMS plans to engage stakeholders to develop condition and specialty-specific MVPs. This is good news for providers who need to focus on Covid-19 response for the remainder of 2020, rather than preparing for MVPs next year. This delay also gives providers more opportunities to weigh in on how CMS should implement MVPs in the future.
- ACOs must review and refine their quality reporting strategy While the proposal to sunset the CMS Web Interface would reduce the number of measures ACOs need to track and report, many organizations have invested heavily in technology and processes to support those measures. ACOs should assess whether to shift their reporting strategy toward MIPS CQMs (registry measures) or eCQMs (EHR measures)—the good news is that those options offer the same measures that are included in the CMS Web Interface.