Key Dates for MIPS 2021 Reporting
COVID-19 and 2021 MIPS Participation
The 2019 Coronavirus (COVID-19) public health emergency continues to impact all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2021 performance year, CMS will continue to use the Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID -19 public health emergency. The application will be available in Spring 2021 along with additional resources.
For more information about the impact of COVID-19 on Quality Payment Program (QPP) participation, see the QPP COVID-19 Response webpage.
- December 2020: Initial 2021 MIPS eligibility status information available
- January 1, 2021: 2021 Performance Year begins
- December 2021: Final 2021 MIPS eligibility status information available
- December 31, 2021: 2021 Performance Year ends
- January 3, 2022: Submission period opens for 2021 Performance Year
- March 31, 2022: Submission period closes for 2021 Performance Year
- July 2022: Final performance feedback available for the 2021 Performance Year
- January 1, 2023: MIPS payment adjustments for the 2021 Performance Year go into effect
Performance Year 2021
Clinicians can use the updated CMS Quality Payment Program Status Lookup Tool to check initial 2021 eligibility for the MIPS program. By entering a National Provider Identifier in the lookup tool, providers can determine eligibility for the 2021 performance period. Eligibility does change during the second half of the year, so it is recommended that clinicians check their status throughout the year. Final eligibility will be available by December 2021.
MIPS Changes in PY 2021
The Merit-based Incentive Payment System is raising the performance threshold points from 45 in 2020 to 60 points in 2021. This significant jump will make avoiding a negative payment adjustment more difficult.
- CMS continues to incrementally adjust the performance threshold and performance category weights to meet the requirements established by MACRA.
- The exceptional performance threshold will remain at 85 points.
- CMS has adjusted the performance category weights from 2020 for 2021:
- Quality: 40% (5% decrease from PY 2020)
- Cost: 20% (5% increase from PY 2020)
- Improvement Activities: 15% (no change from PY 2020)
- Promoting Operability: 25% (no change from PY 2020)
Important changes have been made in the Quality category.
- For 2021, CMS finalized policy to address substantive changes to 113 existing MIPS quality measures (7 of which had substantive changes that do not allow comparison with historical data).
- CMS removed 11 quality measures and added 2 new administrative claims measures.
- CMS will also sunset the CMS Web Interface as a collection and submission type but will extend the availability of the CMS Web Interface as a collection and submission type for one year for the 2021 PY.
In the Cost category, CMS updated the existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the Total Per Capita Cost (TPCC) measure
- CMS increased weighting of the Cost category from 15% to 20% for individuals, groups, and virtual groups reporting traditional MIPS
- CMS is weighting the Cost performance category at 0% for APM Entities reporting traditional MIPS.
Improvement Activities Category
- CMS has maintained the weighting of the Improvement Activities category at 15%
- For PY2021, CMS modified 2 existing improvement activities and removed 1 improvement activity that is obsolete.
- CMS is continuing the COVID-19 clinical data reporting improvement activity with modification as outlined in the September 2020 Interim Final Rule with Comment (IFC).
- CMS has established policies in relation to the Annual Call for Activities including an exception to the nomination period timeframe during a public health emergency (PHE) and an additional new criterion for nominating new improvement activities (“Include activities which can be linked to existing and related MIPS quality and cost measures, as applicable and feasible”).
- CMS has established a process for agency-nominated improvement activities.
Promoting Interoperability Category
- CMS has maintained the weight of the Promoting Interoperability category at 25%.
- CMS retained the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure worth 10 bonus points.
- CMS changed the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information by replacing “incorporating” with “reconciling”.
- An optional Health Information Exchange (HIE) bi-directional exchange measure was added as an alternative reporting option to the 2 existing measures for the HIE objective.
- Certified Electronic Health Record Technology (CEHRT) requirements were updated in response to the ONC 21st Century Cures Act Final Rule.
For more information and resources, visit the CMS Quality Payment Program Resource Library
For questions regarding 2021 final requirements, contact the Health Policy team at [email protected]