MIPS 2021: Final Rule Key Takeaways

MIPS Value Pathways (MVPs)

CMS has finalized updates to the guiding principles to help define what MVPs will look like in the future. Implementation of MVPs will not occur in 2021 as previously anticipated, but will be available in 2022.

APM Performance Pathway

CMS has finalized the APM Performance Pathway (APP), a new reporting framework complementary to MVPs, to begin in 2021. This framework is available only to APM participants and is composed of a fixed set of measures for each performance category.

• The Cost category will be weighted at 0%
• The Improvement Activities score will be automatically assigned based on the requirements of the MIPS APM in which the MIPS eligible clinician participates
• Promoting Interoperability will be reported and scored at the individual or group level
• The Quality measure set will consist of:
  • The CAHPS for MIPS survey measure
  • 2 measures that will be calculated by CMS using administrative claims data
  • 3 quality measures that can be reported as electronic clinical quality measures (eCQMs), MIPS CQMs, or Medicare Part B claims measures

Performance Category Weights

In 2021, the Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.

Performance Threshold

For the 2021 performance period, the performance threshold (maximum number of points needed to avoid a negative payment adjustment) from 45 to 60 points.

Performance Categories

Quality Category

CMS announced in the proposed rule earlier this year its intent to 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. Due to timing concerns because of the Public Health Emergency, CMS has decided to extend the availability of this submission type through 2021, and will sunset the CMS Web Interface in 2022. CMS had also proposed to use performance period benchmarks, rather than historical, to score quality measures in the 2021 performance year. However, it was decided in the final rule to continue with the use of historical benchmarks.

Improvement Activities Category

Minimal updates will be made to the Improvement Activities inventory. CMS will also create policies to include an exception to the Annual Call for Activities nomination period timeframe during a public health emergency, as well as an additional new criterion for nominating new improvement activities. In 2021, there are no changes to the requirement that at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.

Cost Category

CMS will update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the TPCC measure.

COVID-19 Flexibility Scoring

For the 2020 performance period only, the maximum number of bonus points available for the complex patient bonus would be 10, to account for the additional complexity of treating patients during the COVID-19 public health emergency.

Third-Party Intermediaries

Third-party intermediaries such as Qualified Clinical Data Registries (QCDRs), Qualified Registries (QRs), and health IT vendors will be allowed to support the APM Performance Pathway starting in 2021, and the MVP framework starting in 2022. CMS will establish specific data validation requirements for QCDRs and QRs. In performance year 2021, all third-party intermediaries will be required to attend and complete training and support sessions as specified by CMS.

MIPS and SurveyVitals

SurveyVitals can help you satisfy certain MIPS requirements. Learn more on our MIPS page, sign up for a demo, or chat with us using the blue chat icon below.