CMS Proposed 2021 QPP Rule
Aug 10, 2020CMS Releases 2021 Proposed Rule for the QPP
On August 3, the Centers for Medicare and Medicaid Services (CMS) proposed changes to the Medicare Physician Fee Schedule for 2021. The proposed rule includes updates to the Medicare Quality Payment Program (QPP) and Medicare Shared Savings Program (MSSP) for the 2020 and 2021 performance years. Here is what you need to know about the proposed rule.

Key Proposed Rule Updates for the 2021 QPP Performance Year

Recognizing the effects of COVID-19 on clinicians and groups, CMS seeks limited changes to the QPP for 2021. These include delaying the new Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs), updating performance thresholds and weights, and making changes to QPP reporting.

MVP Delayed

In the 2020 Physician Fee Schedule Final Rule, CMS proposed implementing the MVP QPP reporting pathway in 2021. The new proposed rule delays the MVP to 2022 to allow more time for stakeholder input. Instead, CMS is introducing a new APM Performance Pathway (APP) in 2021 aligned with the MVP framework. If you or your group were considering the MVP pathway, you now have more time to comment on CMS’ proposed framework and guiding principles.

Proposed Rule Updates to 2021 QPP Performance Thresholds and Category Weights

The rule also proposes 2021 QPP performance thresholds and category weights. The rule sets an overall performance threshold of 50 points for 2021, up from 45 points in 2020. This is lower than the 60-point threshold CMS has planned for 2021 before the coronavirus pandemic. The category weights for 2021 are as follows:
  • The Quality performance category weight decreases from 45% in 2020 to 40% in 2021
  • The Cost performance category weight increases from 15% in 2020 to 20% in 2021. By law, the Cost performance category weight must increase to 30% in 2022.
  • The Promoting Interoperability performance category remains weighted at 25%.
  • The Improvement Activities performance category remains weighted at 15%.
The rule also proposes updates to the measures included in each performance category, such as:
  • Quality: Use 206 quality measures in the 2021 performance year, including two new claims-based measures. Use performance period benchmarks rather than historical benchmarks to score quality measures to limit the effects of COVID-19 on benchmarking results. End MIPS quality reporting through the CMS Web Interface.
  • Cost: Update measure specifications to include telehealth encounters where appropriate.
  • Improvement Activities: Establish policies and criteria for nominating new improvement activities.
  • Promoting Interoperability: Award 10 bonus points for the Query of Prescription Drug Monitoring Program (PDMP) optional measure. Add a new optional measure for Health Information Exchange (HIE) bi-directional exchange.

Proposed Rule Changes to 2021 QPP Reporting

CMS is also proposing several changes to QPP reporting in 2021. First, CMS seeks to end quality data collection through the CMS Web Interface for Accountable Care Organizations (ACOs), registered groups, and virtual groups. If you used the CMS Web Interface for QPP reporting in prior years, this may be a big change for your organization. However, this proposal should ultimately allow you to report fewer quality measures that are more aligned to your scope of practice, saving you time in future reporting years.The rule also proposes changes to QPP reporting for APMs. In 2020, if you participated in a MIPS APM, you were required to report your data through your APM Entity under the APM Scoring Standard. In 2021, CMS will phase out the APM Scoring Standard. You will be able to participate in the 2021 MIPS as an individual, a group, a virtual group, or an APM entity.Finally, CMS hopes to improve partnerships with third-party intermediaries like Qualified Clinical Data Registries and Qualified Registries. The rule proposes new requirements for third-party intermediaries and allows them to support the new APM Performance Pathway in 2021. If your organization uses a third-party intermediary, these changes should ease your reporting burdens and improve the services you receive.A complete list of the proposed changes to the QPP for 2021 is available here.

The New APM Performance Pathway

CMS has developed a new APM Performance Pathway (APP) for 2021. The APP is complementary to the MVP that will be implemented in 2022. If you or your organization participates in a MIPS APM, the APP will help streamline your QPP reporting.The APP includes a fixed set of measures for each performance category. The 2021 performance categories and weights for the APP are as follows: 
  • The Cost performance category is weighted at 0%, as APMs are already responsible for cost containment.
  • The Improvement Activities performance category is weighted at 20%. In 2021, all APMs will automatically earn a score of 100% in this category.
  • The Quality performance category is weighted at 50%. This category will include six measures focused on population health.
  • The Promoting Interoperability performance category is weighted at 30%.
The quality measures reported through the APP will also satisfy the reporting requirements of the MSSP, so you will only need to report once for both programs. You will also be able to report APP measures at the clinician, group, or APM Entity level. This is a change from 2020 when APMs had to report measures at the APM Entity level.A list of proposed quality measures for the APP is available here.

Key Updates to the Medicare Shared Savings Program in 2021

If you participate in an ACO enrolled in the MSSP, the proposed rule should help reduce your data collection and reporting burdens. There are two key changes to MSSP reporting for 2020 and 2021:
  1. Waive the ACO Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey requirement in 2020. CMS will give ACOs an automatic full credit for CAHPS for the 2020 performance year.
  2. Report quality measures via the APP in 2021 to determine shared savings and losses. Under this proposal, ACOs will only need to actively report 3 measures instead of 10. The APP measures will count toward both QPP and MSSP requirements.
CMS is also proposing to raise the quality performance standard for ACOs participating in the MSSP. In the 2021 performance year, your ACO will need to receive quality scores at the 40th percentile or above in each performance category to be eligible for shared savings. If your ACO meets that threshold, you will earn maximum shared savings.

The New 2020 Complex Patient Bonus for COVID-19

The proposed rule includes a change to 2020 QPP policies to help offset the effects of COVID-19. CMS seeks to increase the complex patient bonus for 2020 from a five-point maximum to a ten-point maximum. If you are a clinician, group, virtual group, or APM Entity, this change could increase your 2020 performance period scores.

How TempDev Can Help

TempDev’s quality consultants can review the proposed changes to the QPP and advise you on the best course of action. Keeping up with QPP policies is a challenge, and TempDev can help you focus on those changes most likely to affect your practice or group. The consultants at TempDev can also help you optimize workflows to meet or exceed MIPS performance measures, even during COVID-19.Call us at 888.TEMP.DEV, or contact us here to get started.