MIPS 2021 Requirements

What’s the biggest change to MIPS in 2021?

To the individual clinician, it’s that they have greater control of their score and incentive money than before.

That’s because CMS changed the previous rule that eligible clinicians reporting through an APM (like an ACO) get the APM’s score regardless of individual performance. This year, clinicians can report their own information and CMS will take the clinician’s highest score, whether that’s in an ACO, or as part of a group, or even their own individual performance. Translation, you may be able to make more money than before.

To an ACO, the big news is two-fold. Firstly, all ACOs that are part of the Medicare Shared Savings Program (MSSP) must use a brand-new framework to report for their practices. Secondly, the CMS Web Interface submission method that ACOs and clinician offices have used to report MIPS to CMS is going away in 2022. That means by the beginning of next year, ACOs and clinician practices need to figure out another way of reporting their practice’s data whether that’s reporting MIPS CQMs, eCQMs or a combination. Figuring out data aggregation will be key for ACOs this year.

Let’s dive into the details.

Understanding MIPS Participation Eligibility

Before we begin, let’s review the types of MIPS participants to understand your options better.

CMS puts Eligible Clinicians into one or more categories.

• Not eligible
  • Clear enough.
• MIPS Eligible Clinician Individual
  • As an individual clinician you are required to report to MIPS.
• MIPS Eligible Clinician Group
  • As an eligible clinician you are required to report to MIPS, and you are able to report as part of a group. Groups are made up of clinicians who all bill with the same Tax ID (TIN).

• MIPS Eligible Clinician Virtual Group
  • As an eligible clinician you are required to report to MIPS, and you are able to report as part of a virtual group. Virtual groups must be comprised of 10 or fewer Eligible Clinicians and, as a group, exceed the low-volume threshold.

• Qualifying APM Participant (QP)
  • This clinician is a part of an Advanced APM Entity and therefore does not have to report to MIPS and automatically receives a +5% payment.
    
    

• MIPS APM Participant
  • This clinician is part of an APM Entity, but it is not an Advanced APM, therefore they still must submit data for MIPS.
    
    

One more thing I’ll add here is that those participation statuses apply to the NPI associated with each provider. We will also be referencing APM Entities in the information below. An APM Entity is responsible for reporting to the MIPS program on behalf of their participants. There are Advanced APMs which take on some form of financial risk. These organizations do not have to report to MIPS. There are other APM Entities which are not designated as advanced. ACOs make up a good portion of these types of organizations. 

As an individual clinician you may have relied on your ACO to report on your behalf.

To find out your participation framework you must check your eligibility on the QPP website.

CMS released a brand-new reporting framework

Once you know your participation status, you will understand which framework you can use for submission. There are two MIPS frameworks in 2021, the Traditional MIPS Framework and the APM Performance Pathway (APP) Framework.

Traditional MIPS Framework

This is the usual MIPS framework made up of four categories and a composite score.

APM Performance Pathway (APP) Framework

The APP Framework is new and is available to MIPS APM entities and required for ACOs if they are part of MSSP.

Here is a matrix of which framework you can report to, based on your status.

Each framework has slightly different requirements and different category weights.

MIPS Framework Category Weights

APP Framework Category Weights

Now before we move on to the category requirements, we need to clarify one more definition, collection types.

Defining MIPS Collection Types

Collection types are the way you report the data to CMS. You can think of them like measures. There are six collection types in 2021.

1. eCQMs (Electronic Clinical Quality Measures)
2. MIPS CQMs (previously called Registry measures)
3. QCDR measures (Qualified Clinical Data Registry)
4. Medicare Part B Claims measures
5. CAHPS for MIPS survey
6. CMS Web Interface measures

As I mentioned before, CMS Web Interface is going away next year so if this is the primary way you submitted your MIPS measures before, you need to figure out a new collection type for 2022.

Which collection type you can submit depends upon your participation status. For instance, CMS Web Interface measures can only be submitted by groups with 25 or more eligible clinicians.

Now we are ready to review the requirements for each framework.

2021 MIPS Quality Requirements