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QPP updates: MVP Pathways postponed, threshold raised

The Quality Payment Program is delaying a major overhaul planned for 2021: Its MVP (MIPS Value Pathways) upgrade, which was meant to move participants “away from siloed activities and measures and towards an aligned set of measures that are more relevant to a clinician’s scope of practice,” has been delayed due to “stakeholder concerns” and COVID-19 (PBN 8/15/19 [subscription required]). Instead, CMS will make “additions to the framework’s guiding principles and development criteria” for 2022.
Higher performance threshold, slight category changes. The performance threshold MIPS participants must meet to avoid penalties is 50 points – up from 45 in 2020. That marks a smaller jump than the 30-to-45-point change in 2020. In the category thresholds, there is also little change:
  • Quality: 40% (5% decrease from PY 2020).
  • Cost: 20% (5% increase from PY 2020).
  • Promoting Interoperability: 25% (no change from PY 2020).
  • Improvement Activities: 15% (no change from PY 2020).
Remember that by law the Cost and Quality performance categories must be equally weighted at 30% beginning in the 2022 performance period.
Other category changes
Quality. Due to COVID concerns over 2020 scoring, CMS will use performance period benchmarks rather than historical benchmarks to score quality measures for the 2021 performance period – that is, the benchmark will either be “based on the actual data submitted during the CY 2021 performance period” or on 2019, pending comments.
CMS plans to remove 14 quality measures from the current 112 measures and add 108 for a total of 206; these include two new administrative claims-based measures, one of which has a three-year measurement period.
Cost. For episode-based cost measures and the Total Per Capita Cost (TPCC) measure, CMS will update existing measure specifications to include telehealth services that are directly applicable.
Promoting Interoperability will make its Query of Prescription Drug Monitoring Program (PDMP) measure optional, for 10 points; “Support Electronic Referral Loops by Receiving and Incorporating Health Information” becomes “Support Electronic Referral Loops by Receiving and Reconciling Health Information”; and an optional Health Information Exchange (HIE) bi-directional exchange measure will be added.
Alternative Payment Model (APM) Performance Pathway (APP)
In lieu of MVP, a new APM Performance Pathway (APP) reporting option will be available in 2021 to participants in MIPS APMs and may be reported by the individual eligible clinician, group (TIN) or APM Entity. Shared Savings ACOs will be required to use this option; quality measures reported through the APP are automatically used for purposes of Medicare Shared Savings Program quality scoring. Under APP, the quality performance category will be composed of six measures that are specifically focused on population health and that CMS believes “to be widely available to all MIPS APM participants.”
Other changes
No more APM Scoring Standard. CMS is proposing to end the APM Scoring Standard, and the APM Entity will be a submitter type that can report to MIPS on behalf of associated MIPS eligible clinicians.
End of Web Interface. CMS is “sunsetting” Web Interface as a collection type beginning in the 2021 performance period. CMS says don’t worry, groups can “select their own quality measures instead of reporting on a pre-determined set of measures established under the CMS Web Interface."
QCDRs, QRs get tougher. Qualified Clinical Data Registries (QCDRs) and Qualified Registries get updated standard and data validation requirements.
Complex patient COVID change. CMS proposes to change the maximum number of points available for the complex patient bonus to account for the additional complexity of treating patients during the COVID-19 Public Health Emergency, up to 10 bonus points (from five).
Also, APM Entities can apply to reweight MIPS performance categories “as a result of extreme and uncontrollable circumstances.”
Shared Savings program
CMS means to change the Shared Savings quality performance standard and quality reporting requirements to align with its previously announced “Meaningful Measures” program. To that end, ACOs participating in the Shared Savings Program will have to report their quality measures through the APM Performance Pathway (APP). As mentioned above, ACOs will be required to use the APM Performance Pathway (APP) reporting option for quality measures.
For performance year 2020, all ACOs are considered to be affected by both COVID-19 and the Shared Savings “extreme and uncontrollable circumstances policy.” The big change for ACOs here is that for 2020 the Consumer Assessment of Healthcare Providers and Systems (CAHPS) requirement is waived and ACOs get automatic full credit for the patient experience of care measures. Other changes will be considered.
CMS also proposes to add E/M and care management codes in the methodology used to assign beneficiaries to Shared Savings ACOs.
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