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2021 QPP Proposed Rule Fact Sheet

See attached Fact Sheet for more details.

Participation Options

We are proposing to end the APM Scoring Standard beginning with the 2021 performance period. Additionally, we are proposing to add the APM Entity as a submitter type which may report to MIPS on behalf of associated MIPS eligible clinicians. The APM Entity would be defined by the Participation List or Affiliated Practitioner list of the applicable MIPS APM. The APM Entity would be able to report on the Quality and Improvement Activities performance categories. Quality measures could be selected and reported in the same manner and using the same options that are available to all other MIPS eligible clinicians, or could be reported through the APP. When an APM Entity chooses to report to MIPS, we would generally calculate a Promoting Interoperability performance category score for the APM Entity group.

Performance Threshold and Performance Category Weights

We are proposing the following performance threshold and category weights for the 2021 performance period (which equates to the 2023 payment year):

• The performance threshold to be 50 points

• The Quality performance category to be weighted at 40% (5% decrease from PY 2020)

• The Cost performance category to be weighted at 20% (5% increase from PY 2020)

• The Promoting Interoperability performance category to be weighted at 25% (no change from PY 2020)

• The Improvement Activities performance category to be weighted at 15% (no change from PY 2020)

In the CY 2020 PFS Final Rule, we had finalized a performance threshold of 60 points for the 2021 performance period but are proposing and soliciting comment on a lower performance threshold of 50 points. By law, the Cost and Quality performance categories must be equally weighted at 30% beginning in the 2022 performance period.

Performance Category Proposals

For the Quality performance category, we are proposing to:

• Use performance period, not historical, benchmarks to score quality measures for the 2021 performance period. We are concerned we may not have a representative sample of historic data for CY 2019 because of the national public health emergency for COVID-19 (which impacted data submission in 2020), which could skew benchmarking results.

• Update the scoring policy for topped-out measures, so that the 7 measure achievement point cap will be applied only if the measure is identified as topped out based on the established benchmarks for both the 2020 and 2021 performance periods, given that we are proposing to use performance period, not historical, benchmarks for the 2021 performance period;

• Address substantive changes to 112 existing MIPS quality measures, removing 14 quality measures from the MIPS program, and proposing a total of 206 quality measures starting in the 2021 performance year, including two new administrative claims-based measures, one of which has a 3-year measurement period;

• Revise scoring flexibility for measures with specification or coding changes during the performance year; and

• End the CMS Web Interface as a quality reporting option for ACOs and registered groups, virtual groups, or other APM Entities beginning with the 2021 performance period.

For the Cost performance category, we are proposing to:

• Update existing measure specifications to include telehealth services that are directly applicable to existing episodebased cost measures and the TPCC measure.

For the Improvement Activities performance category, we are proposing to:

• Make minimal updates to the Improvement Activities Inventory;

• Establish policies in relation to the Annual Call for Activities including an exception to the nomination period timeframe during a public health emergency (PHE) and a new criterion for nominating new improvement activities; and

• Establish a process for agency-nominated improvement activities.

For the Promoting Interoperability performance category, we are proposing to:

• Retain the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure and propose to make it worth 10 bonus points;

• Change the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information by replacing “incorporating” with “reconciling”; and

• Add an optional Health Information Exchange (HIE) bi-directional exchange measure

For third party intermediaries, such as Qualified Clinical Data Registries (QCDRs) and Qualified Registries, we are:

• Proposing to allow QCDRs, Qualified Registries, and Health IT vendors to support:

  • MVPs beginning with the 2022 performance period
  • The APM Performance Pathway (APP) beginning with the 2021 performance period

• Proposing to establish specific data validation requirements for QCDRs and Qualified Registries, and seeking comment on whether Health IT Vendors and CAHPS survey vendors should perform similar data validation.

• Proposing that the following additional factors will be considered when determining whether to approve a third party intermediary for future participation in the MIPS program:

  • The entity’s compliance with the requirements of this section for any prior MIPS performance period for which it was approved as a third party intermediary.
  • Whether the entity provided inaccurate information to the clinicians regarding Quality Payment Program requirements.

• Updating the standards for QCDR measures (details in the table below):

  • Modifications to the QCDR measure testing requirement o QCDR measures must be fully tested at the clinician level in order to be considered for inclusion in an MVP.
  • Modifications to the QCDR measure data collection requirement

Lastly, we are proposing to require additional information be submitted to CMS as part of the corrective action plans under the remedial action and termination policies applicable to all third party intermediaries.

Scoring Proposals (COVID-19 Flexibilities for PY 2020)

We are proposing to change the maximum number of points available for the complex patient bonus to account for the additional complexity of treating patients during the COVID-19 Public Health Emergency. As proposed, clinicians, groups, virtual groups, and APM Entities could now earn up to 10 bonus points towards their final score for the 2020 performance year.

We are proposing this increase for the 2020 performance period only.

We are also proposing to allow APM Entities to submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. This policy would apply beginning with the 2020 performance period.

Physician Compare Finally, to more completely and accurately reference the website for which CMS will post information available for public reporting we propose to define Physician Compare to mean the Physician Compare Internet Web site of the Centers for Medicare & Medicaid Services (or a successor Web site).