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.
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.
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.
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.
This is the usual MIPS framework made up of four categories and a composite score.
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.
Now before we move on to the category requirements, we need to clarify one more definition, 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.
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.
There are many opportunities to get bonus points within the MIPS program.
Improvement Bonus: Up To 10 Points
Clinicians will be rewarded if they demonstrate any improvement to their 2021 Quality score over the prior year (pending there is enough data for comparison).
Electronic Submission: Up To 6 Points
Receive up to 6 bonus points by submitting your Quality measures via electronic submission.
Additional Measure Submission: Up To 6 Points
By submitting additional Outcome (2 points) High Priority measures (1 point) in the Quality category, you can be rewarded up to 6 bonus points.
PDMP Measure Bonus: Up To 10 Points
Report on the Query of Prescription Drug Monitoring Program measure to receive 10 bonus points.
Complex Patient Bonus: 5 Points
For clinicians who work with patients that have more complex cases, CMS will award up to 5 points to account for the additional complexity of treating their patient population.
Small Practice Bonus: 6 Points
An additional 6 bonus points will be added to the numerator of the Quality category for anyone qualifying as a small practice.
To avoid a -9% penalty, you must score at least 60 points.
To be eligible for bonus money you must score at least 85 points (Exceptional Performance Bonus).
0-15 Points
If your score is between 0 and 15 points in 2021, you will lose -9% from your 2023 Medicare fee schedule (in red above).
15.01-59.99 Points
If your score is between 15.01 and 59.99 points you will receive a reduction to your 2023 Medicare fee schedule between -8.99% and 0%
60 Points
60 points is the performance threshold. If you achieve 60 points you receive a 0% adjustment.
60.01.-100 Points
CMS will take the funds of those who did not meet the threshold (in red) and distribute them among those who did meet the threshold (in green). Anyone whose MIPS score is between 60.01 and 100 points will receive some portion of those funds – up to a 9% increase to their 2023 Medicare fee schedule.
85 Points and above
By scoring at least 85 points, you’ll be eligible for the Exceptional Performance bonus money (on the right). CMS has set aside an additional $500 million to distribute to anyone who scores between 85 – 100 points. This is on top of whatever portion of money you receive from those who do not participate (in red).
Note: Exceptional Performance bonus can be earned until Measurement Year 2022, Payment Year 2024
January 1, 2021 is the start date to track 365 days of Quality and Cost category measures. For the Promoting Interoperability category and the Improvement Activities category, you may start between January 1 and October 2, 2021 to track your measures for a minimum of 90 days.
The last day to submit all of your performance data is March 31, 2022.
|