P3Care Investigates QPP MIPS 2021 Proposed Rules

CMS (The Centers for Medicare and Medicaid Services) released the proposed rule for QPP MIPS 2021 via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

In this article, we dissect changes that are expected to appear in MIPS 2021. However, keep in mind that the changes are just propositions and are not final yet.

Each year, CMS proposes various guidelines to facilitate physicians with their payments.

How MIPS consultants take care of the administrative data to report to the authorities affects revenue cycles. How to report MIPS data is what adds to your revenue year after year, especially for clinicians associated with Medicare.

Physicians Services Translate into Patient Care

As physicians, your first responsibility is towards your patients. For a fact, you would not have time to manage the MIPS reporting 2021 requirements, given the situation with COVID. With all of what’s going on, I am sure you want to begin 2021 on a high note. The help of MIPS consulting services, make the process of MIPS data submission easier and less hectic.

Besides accurate data reporting, we also have to understand the QPP MIPS requirements every performance year.

What can we expect in the MIPS 2021, and how it will impact the data submission process. Let’s follow-through.

But, first, we must analyze the COVID-19 Impact!

2021 QPP MIPS might come with challenges. We can expect time delays (which we also experienced during MIPS 2020 performance period).

The implications of the pandemic are going to go a long way with us. For instance, CMS asks physicians to focus on the quality of care rather than the volume of patients. However, with the pandemic, there was no choice left other than catering to the volume of patients while being careful and value-driven to every extent possible.

Therefore, a delay in the implementation of MIPS Value Pathways (MVPs) for 2021 seems only reasonable.

Additional reporting flexibilities are also in consideration in response to the COVID-19. Talk about MIPS incentives, they are by far the most as compared to the previous years. Realistically speaking, P3Care can get you up to +5% positive payment adjustments for its clients. Fill the form that appears in the pop-up and we’ll get back to you shortly.

MIPS Value Pathways (MVPs)

The proposed rule stated that MIPS Value Pathways (MVPs) will be delayed until 2022.

However, they will be available as options, and eligible clinicians can choose to report through them alongside the other MIPS data submission options.

APM Performance Pathways

Participants of MIPS APMs are allowed to report via APPs, which function the same as MVPs.

CMS is also considering sunset the current APM score standards in 2021.

Keep in mind that only the following audience can use APPS.

Individual eligible clinician
Group (TIN) or APM Entity
MIPS APM participants

The above-mentioned specialists have the option to use APP, but it is compulsory for ACOs participating in the Medicare Shared Savings Program to report quality performance via the APP.

The performance category for the APP will be scored as follows upon the fixed set of quality measures.

Quality Category: Weighs 50%. It contains six measures that focus on population health.

Improvement Activities (IA) Category: Weighs 20%. CMS will automatically assign its score based on the requirements of the MIPS APM.

All APM participants reporting through the APP will earn a 100% score for 2021.

Promoting Interoperability (PI) Category: Weighs 30%. Compulsory for all QPP MIPS data submissions. It is reported and scored at the individual or group level.

Cost Category: Weighs at 0%

Moreover, it is also automatically used for the Medicare Shared Savings Program (MSSP) quality scoring.

QPP MIPS Program Updates

For MIPS 2021, various data submission options will be given to MIPS consulting services to help eligible clinicians get through the program.

Physicians have the option to report QPP MIPS as:

Virtual Group
Solo eligible Clinicians
Group
APM Entity

Note that the virtual group has the highest hierarchical priority when CMS receives multiple scores for it.

APM Participation

Participation through APM participation is available for eligible clinicians. They can report QPP MIPS data for both Quality and Improvement Activities (IA) performance categories.

Moreover, you can select and report MIPS Quality measures in the same manner as eligible clinicians choose and report for QPP MIPS.

However, generally, the APM Entity group calculates the performance for the Improvement Activities (IA).

The Cost category has a slight change in the data reporting mechanism. If you do not report this category via APP, the APM Entity Group will automatically score it.

The above-mentioned are the little details that QPP MIPS participants must know beforehand they enter the MIPS 2021.

Until now, you must have a good idea of the minor changes that are expected in QPP MIPS 2021. Now, it’s time to look into details of (Centers for Medicare and Medicaid Services) CMS-published Proposed Rule. Some adjustments are made to simplify administrative data while others in response to the corona pandemic.

Let’s get started!

Proposed Sunset of Web Interface Mechanism

CMS in the Final Rule aims to facilitate groups and virtual groups with MIPS data submission 2021. They proposed a sunset of the CMS Web Interface as a new reporting method. It is particularly useful for larger group participants of QPP MIPS 2021, APM (Alternative Payment Model), and the MSSP (Medicare Shared Savings Program).

It is because of the CMS data indicating a 45% reduction in the usage of the mechanism. Moreover, there is a 40% reduction in utilization of CMS Web Interface.

If this rule comes into effect, MIPS eligible groups and virtual groups can then report relevant data via a MIPS Qualified Registry or EHR (Electronic Health Records).

Crucial Changes in APM Reporting

Many APM participants may use APP (APM Performance Pathway) for quality reporting.

CMS also suggests setting six quality measures for APM reporting naming:

Controlling High Blood Pressure
Diabetes: Hemoglobin A1c Poor Control
Preventive Care and Screening: Screening for Depression and Follow-up Plan
Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs
Hospital-Wide, 30-day, All-Cause Unplanned Readmission Rate for MIPS Eligible Clinician Groups

This step aims to simplify the administrative load to help focus physicians on quality patient outcomes.

ACO (Accountable Care Organization) Reporting

Under QPP MIPS 2021, the proposed rule suggests Shared Savings ACOs reporting with the following changes.

There is an availability of several data submission methods for ACOs stating who will submit what data to CMS. For Instance, instead of the ACO entity submitting data by itself, allowing participants to submit data at the individual level.

The operational and strategic changes will allow ease in the reporting process. Of course, data collection and aggregation is a problem that often hinders the pace of MIPS reporting. However, with this step, we can observe potential improvement in data submission and the MIPS score.

How to Adjust with the Changes in MIPS Data Submission Process?

Here to remember that the proposed rule might be different from the final rule. But, even if the reporting requirements changes, they must be somewhat similar. The best option is to get in touch with professional MIPS consulting services to comply with the required changes.

Conclusion

QPP MIPS 2021 is different from the previous years in terms of quality reporting. The pandemic is still not over yet, and the focus on patient empowerment through value-based outcomes has increased noticeably.

We also understand that adjusting to new reporting requirements takes time. However, the comprehension process of MIPS reporting 2021 criteria becomes easy when you have professional MIPS consultants with you.

To begin with, medical practices should design their strategic goals to align their efforts. It is just the start of the performance year, so you can experiment with different measures. It is an opportunity to compensate for the lost revenue during the pandemic emergency by delivering QPP MIPS 2021 performance. We should not miss it.