The QPP Quest
Special Edition
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Vol. 3 Ed.13 | December 7, 2020 |
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2021 Quality Payment Program Final Rule Released!
Note: As with other rules, CMS is publishing this Final Rule to meet the legal requirements to update Medicare payment policies in the PFS on an annual basis. In recognition of the 2019 Coronavirus (COVID-19) public health emergency and limited capacity of healthcare providers to review and provide comment on extensive proposals, CMS has limited annual rulemaking required by statute to focus primarily on essential policies, including Medicare payment to providers, as well as changes that reduce burden and may help providers in the COVID-19 response.
2021 QPP Final Rule Highlights
The key policies included for QPP include:
- Beginning Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) implementation in 2022.
- Increasing the performance threshold at 60 points for 2021.
- Revising performance category weights for Quality (decreases from 45% to 40%) and Cost (increases from 15% to 20%).
- Extending the use of the CMS Web Interface as a collection and submission type for reporting MIPS quality measures in 2021 and sunsetting the option beginning with 2022.
- Sunsetting the Alternative Payment Model (APM) Scoring Standard and allowing MIPS-eligible clinicians in APMs the option to participate in MIPS and submit data at the individual, group, virtual group, or APM-Entity level.
- Updating third party intermediary-approval criteria as well as remedial action and termination criteria.
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CMS Finalizes New APM Performance Pathway for 2021
CMS will implement the APM Performance Pathway (or APP) in 2021. Performance category weights under the APP will be: 50% for Quality, 30% for Promoting Interoperability, 20% for Improvement Activities, and 0% for Cost.
The APM will be:
- Complementary to MVPs, composed of a fixed set of measures for each performance category.
- Available as an option only for MIPS eligible clinicians in MIPS APMs.
- Reported by individual eligible clinicians, groups, or APM Entities.
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Complex Patient Bonus COVID-19 Update in 2020
The final rule also increases the complex patient bonus from a 5 to 10-point maximum for clinicians, groups, virtual groups, and APM Entities for the 2020 performance year only to offset the additional complexity of their patient population due to COVID-19.
More Information:
To learn more about the PFS Final Rule and the 2021 Quality Payment Program finalized policies, review the following resources:
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Press Release—Provides additional details regarding the Medicare PFS Final Rule.
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QPP 2021 Final Rule Resources (ZIP file)—Contains the following:
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Fact Sheet and Table—Offers an overview of the QPP final rule policies for 2021 and table compares these policies to the requirements for 2020.
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Frequently Asked Questions (FAQs)—Addresses the frequently asked questions for the 2021 QPP final rule policies.
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CMS MVP Submission Template—Provides instructions and a template that stakeholders should use to submit an MVP candidate for consideration.
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MIPS Extreme and Uncontrollable Circumstance (EUC) Policy Application Extended
To further support clinicians during the COVID-19 public health emergency, CMS is extending the 2020 MIPS Extreme and Uncontrollable Circumstances Exception application deadline to February 1, 2021.
If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.
If you have an approved application, you can still receive scores for the Quality, Improvement Activities, and Promoting Interoperability performance categories if you submit data. If the Cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted. Learn more in the 2020 Exceptions Application Fact Sheet.
How To Apply:
You must have a Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS-eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.
How To Determine Approval:
If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.
New: CMS has finalized that for the 2020 performance year, Alternative Payment Model (APM) Entities may submit Extreme and Uncontrollable Circumstances applications as a result of COVID-19. For more information about the impact of COVID-19 on QPP participation, see the QPP COVID-19 Response webpage.
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Upcoming Final Rule Webinars |
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Interoperability and Patient Access Final Rule Call |
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Wednesday, December 9 at 1:30–3:00 p.m. ET
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2021 Quality Payment Program Final Rule Overview
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Wednesday, December 9 at 2–3:00 p.m. ET
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Physician Fee Schedule Final Rule: Understanding 4 Key Topics Call
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Thursday, December 10 at 1:30 p.m.–3:00 p.m. ET
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Town Hall Meeting on MIPS Value Pathways Development |
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Thursday, January 7 at 9:00 a.m.–4:00 p.m. ET
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Implications of the Year 5 Final Rule for Solo and Small Group Practices
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Tuesday, January 12 at 11:00 a.m.–12:00 p.m. ET
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Thursday, January 14 at 3:30–4:30 p.m. ET
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Subscribe to Get the Information You Need |
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Subscribe to HSAG's QPP Quest Digest
Invite your practice staff, practices you refer patients to, and other colleagues to subscribe to HSAG’s QPP Quest Digest! Stay informed of all monthly QPP updates, deadlines, no-cost webinars and best practices by subscribing here.
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CMS QPP Listserv
Don't forget to sign up on the CMS.gov QPP website. Once you've accessed the QPP page, scroll to [Subscribe to Updates] at the bottom of the page and insert your email address before clicking [Subscribe]. The QPP listserv is a valuable resource to stay informed of webinars and important QPP deadlines.
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