How did the COVID-19 pandemic impact the 2021 QPP Final Rule?
Another year is about to start and that means another round of the Quality Payment Program (QPP). It goes without saying that nothing has been normal in the healthcare industry over the course of 2020. The COVID-19 pandemic has turned the world largely upside down, but the hope now with vaccines being rolled out is that we’ve reached the beginning of the end of this public health crisis. So let’s take a look at what we can expect from the QPP for the 2021 performance year.
How will the pandemic of 2020 play into the overall requirements?
As has been the case all around the world, in the United States the focus of clinicians for 2020 has been to respond to the COVID-19 pandemic and ensure that their patients receive quality care in this difficult time. Because of this, the Centers for Medicare & Medicaid Services (CMS) is responding by limiting the number of significant changes to the Quality Payment Program (QPP) for the 2021 program year. One of the biggest changes as compared to the original plan is that MIPS Value Pathways (MVPs) will no longer be required for the 2021 performance year, but instead targeted for a 2022 start. There are also some changes coming with regard to scoring weights, with the Quality performance category being weighted at 40% for 2021, compared to 45% in 2020; the Cost performance category being weighted at 20%, compared to 15% in 2020; the Promoting Interoperability performance category being weighted at 25%, the same as in 2020; and the Improvement Activities performance category being weighted at 15%, the same as in 2020. The Qualified Clinical Data Registry (QCDR) measure is also being delayed by one year, from 2021 to 2022, due to the anticipation that collecting and submitting data on QCDR measures while also prioritizing COVID-19 care and protocols may be too difficult to achieve.
|Performance Category||2020 Performance Year Weight||2021 Performance Year Weight|
|Promoting Interoperability||25%||25% no change|
Where do we stand with the Final Rule?
Public comments on the proposed rule were being accepted until October 5, 2020, and on December 1, 2020 CMS released the Quality Payment Program Final Rule for the 2021 performance year. This final rule covers all changes to both the Merit-based Incentive Payment System (MIPS) and the Alternative Payment Models (APMs) that providers and practices need to become aware of before the performance year begins on January 1, 2021.
What are the major changes and new items compared to 2020?
In light of the pressures of the current public health crisis, there are limited major changes to the Quality Payment Program for the 2021 performance year. The biggest changes are the category weights as we discussed previously, as well as changes to the performance threshold. For 2021 the performance threshold required in order to avoid a payment penalty is 60, compared to 45 in 2020. The additional performance threshold for 2021 will remain at 85. Another change for 2021 is that CMS has proposed the idea of using 2021 data in order to calculate 2021 submission benchmarks due to skewed data from the COVID-19 pandemic. This change would be one to pay special attention to as it would make it difficult to estimate scores in advance, adding some trepidation to the whole process for providers and practices.
What requirements should clinicians watch out for in 2021?
Again, the minimum threshold for 2021 has increased 15 points to 60 points for this new performance year. This, of course, means that you will need to earn at least 60 points in order to avoid a penalty. Should you not earn 60 points and receive a MIPS penalty, there is no change to the MIPS payment adjustment from what it was in 2020, with the adjustment staying at +/- 9%, and adjustment that would affect your reimbursements for the calendar year 2023.
CMS will be sunsetting the Web-Interface Reporting option in 2022, so this is something that practices who have previously participated in this way will want to begin preparing for in 2021. For the 2021 performance year, there will be an option to continue to report through the Web Interface or instead to report under a new Alternative Payment Model (APM) Performance Pathway (APP), which is the way that these practices will be reporting beginning in 2022.
There are also a couple of notable changes coming to the Quality Performance Category. First, there are 12 measures being removed from MIPS in this category in 2021. The measures being removed are:
|12 measures being removed from MIPS in this category in 2021|
|#048||Urinary Incontinence: Assessment of Presence or Absence of Urinary Incontinence in Women Aged 65 Years and Older|
|#069||Hematology: Multiple Myeloma: Treatment with Biphosphonates|
|#146||Radiology: Inappropriate Use of “Probably Benign” Assessment Category in Screening Mammograms|
|#333||Adult Sinusitis: Computerized Tomography (CT) for Acute Sinusitis (Overuse)|
|#348||Implantable Cardioverter-Defibrillatory (ICD) Complications Rate|
|#390||Hepatitis C: Discussion and Shared Decision Making Surrounding Treatment Options|
|#408||Opioid Therapy Follow-Up Evaluation|
|#412||Documentation of Signed Opioid Treatment Agreement|
|#414||Evaluation or Interview for Risk of Opioid Misuse|
|#435||Quality of Life Assessment for Patients with Primary Headache Disorders|
|#437||Rate of Surgical Conversion from Lower Extremity Endovascular|
Also, CMS will be revising the scoring for any measures with coding or specification changes that happen during the performance year. For these measures, the performance data will be based on nine consecutive months of the performance period, and if data either isn’t available or may result in misleading results or patient harm, the measure will be suppressed.
Each new performance year for the QPP brings its own set of jitters, and surely 2021 is no exception after the difficult year we’ve all had in 2020. Thankfully, CMS recognizes the challenges we’ve all faced and has addressed the concerns regarding the QPP without completely scrapping the program and losing progress. There are a few new pieces to be aware of, but nothing earth shattering. And if you want to be sure that you’re prepared, reach out to us here at MicroMD. We are poised and ready to help you make it through QPP for 2021, just as we have been each other year of the program.