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P3Care Investigates: QPP MIPS 2021 Proposed Rule

CMS (The Centers for Medicare and Medicaid Services) released the proposed rule for QPP MIPS 2021 via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

In this article, we will be dissecting changes that are expected in MIPS 2021. However, keep in mind that the changes are just proposed until now and are not final yet.

Each year, CMS proposes various guidelines to facilitate physicians with their payments.

How MIPS consultants take care of the administrative data to report to the authorities affects revenue management.

As a physician, your first responsibility is towards patients. We are sure that you certainly would not have time to manage the MIPS reporting requirements.  However, with the help of MIPS consulting services, the process of MIPS data submission becomes easier and less hectic.

Besides the accurate data reporting, we also have to understand the QPP MIPS requirements every performance year.

What can we expect in the MIPS 2021, and how it will impact the data submission process.  Let’s follow-through.

But, first, we must analyze the COVID-19 Impact!

2021 QPP MIPS might come with challenges. We can expect time delays (which we also experienced during MIPS 2020 performance period).

The implications of the pandemic are going to go a long way with us. For Instance, CMS asks physicians to focus on quality care rather than volume care. However, with the pandemic, there was no choice left other than catering to the volume of patients while being careful and value-driven to every extent possible.

We are expecting a delay in MIPS Value Pathways (MVPs) for 2021.

Additional reporting flexibilities are also in consideration in response to the COVID-19.

MIPS Value Pathways (MVPs)

The proposed rule stated that MIPS Value Pathways (MVPs) will be delayed until 2022.

However, they will be available as options, and eligible clinicians can choose to report through them alongside the other MIPS data submission options.

APM Performance Pathways

Participants of MIPS APMs are allowed to report via APPs, which function the same as MVPs.

CMS is also considering sunset the current APM score standards in 2021.

Keep in mind that only the following audience can use APPS.

  • Individual eligible clinician
  • Group (TIN) or APM Entity
  • MIPS APM participants

The above-mentioned specialists have the option to use APP, but it is compulsory for ACOs participating in the Medicare Shared Savings Program to report quality performance via the APP.

The performance category for the APP will be scored as follows upon the fixed set of quality measures.

Quality Category: Weighs 50%. It contains six measures that focus on population health.

Improvement Activities (IA) Category: Weighs 20%. CMS will automatically assign its score based on the requirements of the MIPS APM.

All APM participants reporting through the APP will earn a 100% score for 2021.

Promoting Interoperability (PI) Category: Weighs 30%. Compulsory for all QPP MIPS data submissions.  It is reported and scored at the individual or group level.

Cost Category: Weighs at 0%

Moreover, it is also automatically used for the Medicare Shared Savings Program (MSSP) quality scoring.

QPP MIPS Program Updates

For MIPS 2021, various data submission options will be given to MIPS consulting services to help eligible clinicians get through the program.

Physicians have the option to report QPP MIPS as:

  • Virtual Group
  • Solo eligible Clinicians
  • Group
  • APM Entity

Note that the virtual group has the highest hierarchical priority when CMS receives multiple scores for it.

APM Participation

Participation through APM participation is available for eligible clinicians. They can report QPP MIPS data for both Quality and Improvement Activities (IA) performance categories.

Moreover, you can select and report MIPS Quality measures in the same manner as eligible clinicians choose and report for QPP MIPS.

However, generally, the APM Entity group calculates the performance for the Improvement Activities (IA).

The Cost category has a slight change in the data reporting mechanism. If you do not report this category via APP, the APM Entity Group will automatically score it.

The above-mentioned are the little details that QPP MIPS participants must know beforehand they enter the MIPS 2021.

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An Insight into QPP MIPS Payment Adjustments in 2020

CMS states that up to ninety-eight percent of the eligible clinicians are expected to receive positive payments in 2020 for the year MIPS 2018. The rate is five percent higher than the previous year.

In the upcoming year, the trend of incentives and reimbursements is going to increase as the quality reporting is supposed to improve via MIPS Value Pathways (MVPs). MVPs will be operational from next year.

MVPs – A Chance to Succeed for Everyone

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In order to translate practice’s expertise in the true sense, we must adopt MVPs. Small medical practices and medical facilities in rural areas irrespective of their operational size can earn rewards for their rendered services. Seeing the numerous benefits of the MIPS program, rural medical facilities are participating more and more each year.  Statistics show that there was a rise of four percent in QPP MIPS participation from 2017 to 2018.

The Report Card for MIPS 2018

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CMS has published the results for MIPS 2018 participation. 889,995 eligible clinicians have reportedly received positive payment adjustment, and 872,148 of them have received neutral payment adjustment.

Seema Verma, CMS administrator is quite happy with the results as it depicts the higher number of physicians opting for quality healthcare delivery systems. The quality outcomes also credit the vision of empowered and cost-effective healthcare industry.

Despite the administrative burden, more and more participants succeed in the QPP MIPS. It is due to the lower performance thresholds, which ultimately reflect on payment adjustment. Moreover, CMS doesn’t want to jump up the positive payment adjustment, as it has to be balanced with the negative payment adjustments.

MIPS Future Holds Higher-Performance Thresholds

CMS has planned to make higher thresholds for exceptional performance to reduce the reward distribution. They are working on a strategy to reward physicians who continuously invest in the quality of healthcare and interoperability, and help patients in many manners. This can be seen in the gradual increase in the performance bar for penalties and bonuses.

Seema Verma also hints on supporting clinicians via reducing the burden and providing opportunities for meaningful services. The No-cost Small, Underserved and Rural Support initiative tends to lend a hand with technical assistance for smooth and optimized performance in the healthcare sector.

This program also creates awareness about the quality care and payment model along with helping eligible clinicians with participation in MIPS.

With the research and taking into account what physicians bring to the table, the future reporting criteria is estimated to only include a framework that flows without stressing physicians unnecessarily.

CMS also wants participants’ feedback on the MVPs’ developments. They are looking forward to advancements that help them drive value to the healthcare industry in terms of payment models, lower administrative burden, and cost-effective patient outcomes.