As someone in-the-know, you may have heard about some recent changes to the Merit-based Incentive Payment System, or MIPS. The past year has presented some significant challenges for the industry, and while some of these changes are merely CMS responding to the present hardships, others are indicative of the agency’s pursuit toward its long-term goals. In this article, we’ll cover the current changes and what you can expect in the future.
To start, we’ll give you a brief update on the current state of MIPS. Recently, there have been some modifications to requirements for MIPS owing to the ongoing COVID-19 pandemic. At the end of last year, CMS announced that it is possible to opt out of one of four categories of MIPS for the 2021 submission year if you felt your practice was adversely affected by COVID-19. More recently, CMS has announced further guidance on this, saying that it will allow all clinicians eligible to participate in MIPS to claim a hardship exemption for the year 2021 owing to COVID-19. This means that, if clinicians request an exemption, they will not be required to report any data, and they will not be subject to any downward payment adjustments for 2023 claims; conversely, they will also not be eligible for a positive adjustment on claims in 2023. While this is available to all who participate in MIPS, it must be applied for, specifically by the end of the year, December 31st, 2021.
CMS also took the time to revise its hardship exemption policy for the 2020 year. Previously, the agency made clear that all clinicians would receive an automatic exemption from all four MIPS performance categories if they did not report any data from 2020, those categories being Quality, Cost, Improvement Activities, and Promoting Interoperability. However, clinicians still had the option to submit data before March 31st if they so chose, which would then in turn make them receive a performance score. CMS has now made it clear that it would not score the Cost category for any 2020 data. This is due to the fact that the agency did not receive a sufficient service volume to reliably calculate cost scores. Returning to those previously mentioned clinicians who chose to submit data (and thus waived their exemption), their final MIPS score will not include their performance in the cost category as a metric.
2021 presents some other MIPS changes as compared to 2020. In the 2021 physician fee schedule released in December of last year, CMS finalized its proposed changes to the performance weights of the Quality and Cost categories for 2021. This was to be expected, as current law dictates the Quality and Cost categories must each be weighted at 30 percent starting in 2022. Still, it is important to note that for the 2021 submission year, the Quality category has been reduced from 45 to 40 percent, while the Cost category has increased from 15 to 20 percent.
Continuing on, the threshold clinicians need to achieve to avoid a penalty has been raised substantially. While 45 points was the standard in 2020, 2021 ups the standard to 60 points, ten more points than its previously-proposed 5 point change. The reason given for this change was that CMS acknowledges that many clinicians have still been able to successfully participate in MIPS and that the impact on practices stemming from COVID-19 has been mixed. For exceptional performance, the standard remains at 85 points.
The positive payment adjustment can be up to 9 percent before performance bonuses, and the maximum negative payment adjustment is negative 9 percent, as required by statute.
Finally, you may have heard about MIPS Value Pathways, or MVPs. While CMS had previously planned to implement them sooner, their implementation has been delayed until at least 2022, and the agency plans on creating new criteria for assessing MVP proposals in the future. Qualified clinical data registries will also be expanded in their capabilities, including the addition of new functionality to support MVPs.
This is the current state of MIPS and this section of the industry as a whole. However, while the pandemic is seeming to be coming to an end, there is a significant chance that there will be more changes in the future if COVID-19 returns or becomes more severe. We will keep you up-to-date with these changes.