For years, we’ve heard that the Merit-based Incentive Payment System (MIPS) will provide a noticeable incentive for participants in this Medicare FFS program. And for years, there have been reasons why that has not occurred. First, CMS wanted to ‘start slow’ with the MIPS program in 2017 and 2018, so the caps on penalties and incentives were small. Then the potential penalties and incentives were raised, but the threshold for qualifying for an incentive remained low. This, coupled with the program’s budget neutrality meant there was not much revenue to distribute to high performers. Then COVID-19 negated much of the program for the last two years. So here we are, in year five, and we see that the program, for the first time, will have a significant downside and upside potential.

The long-awaited CY 2021 Medicare Physician Fee Schedule Final Rule update is now here. Despite the disruptions of the Public Health Emergency COVID-19, participation in performance year 2019 was strong. Thus the 2021 Final Rule moved forward with finalizing a number of proposed changes, including a higher performance threshold for performance year 2021, anticipated changes in weight to the Quality and Cost performance categories of the Merit-based Incentive Payment System (MIPS), and the introduction of the APM Performance Pathway. Other expected initiatives, such as MIPS Value Pathways, the requirement for registries to build their own benchmarks for certain measures, and the sunsetting of the CMS Web Interface, have been pushed back to at least the 2022 performance year.

Starting in January, 920 primary care practices will embark on the one of the newest payment models from the Centers for Medicare & Medicaid Services (CMS) via the Primary Care First (PCF) Program.  The main criteria for participation in the program are:

• 70% or more of the practice’s collective billing must be for primary care services.
• Use of a 2015 Certified Electronic Health Record Technology (CEHRT) by the practice.
• At least 125 services provided for attributed Medicare beneficiaries.

Also, for the first year of the program, there is a limited geographical area for participation.

Clinicians participating in the Merit-Based Incentive Payment System (MIPS) are set to finally receive a worthwhile financial return for 2021 reporting. Providers have been unsure whether incentive returns of less than 2% justifies shifting focus to achieve a high score in the program. A provider collecting $400,000 in Medicare Part B payments in 2020 will only receive $6,700 for scoring well in 2018 quality payment program (QPP) performance. While this does produce a positive return on investment, it may cause practices to question whether it is worth the effort required to track and report measures.

The last 90 days of the year. Many might be ready to say goodbye to 2020 as a year filled with challenges, adjustments and ever-shifting expectations in our personal and professional lives. For those clinicians who are eligible for participation in the Merit-Based Incentive Payment System (MIPS), the last 90 days of the year also represents the beginning of some measurement periods and the final opportunity to improve in others.

The 2021 Proposed Rule was released last week, and there are some potential changes that you should keep your eye on. Scouring through the entire release, it’s apparent that the Centers for Medicare & Medicaid Services (CMS) kept to their two main objectives:

1. Minimize changes to reduce the burden on providers digging out of COVID-19
2. Keep the momentum of the Quality Payment program moving forward

The quick answer is NO!

There has been quite a bit of discussion, and some press, about the reporting period for MIPS for 2020. I have seen a few articles saying that no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in the Center for Medicare & Medicaid Services (CMS’s) calculations for the Medicare quality reporting and value-based purchasing programs. However, if you read the Quality Payment Program – COVID-19 Response, Updated 6/24/2020, there is no mention of an all-inclusive change to the reporting period.

In the last couple of weeks, some major changes have been made to the immediate future of Value-Based Care payment models.

Some of these updates include:

• The extension of the Oncology Care Model (OCM) until June of 2022. The Centers for Medicare & Medicaid Services (CMS) is also giving practices the ability to abdicate downside and upside risk performance during the COVID-19 outbreak.
• The delay of starting the new Direct Contracting model to April 1^st, 2021.
• The extension of the Next-Gen ACO model until December 2021.
• The option for participating entities in the Bundled Payments for Care Improvement Advanced (BPCI) payment model  to eliminate upside or downside risk.
• The removal of COVID-19 episodes of care for certain Medicare ACO models.

Quality and Cost are two fundamental focus areas in the Volume to Value-Based Care transition.  The Centers for Medicare & Medicaid Services (CMS), seeks to incentivize higher quality care at a lower cost through programs like MIPS.  In recent years, the primary focus of MIPS has been Quality reporting, however Quality and Cost will be equally weighted in 2022.  Mandated increases and lack of insight into current MIPS scores make it a top priority for practices to learn how Cost impacts their revenue.

We know the current regulatory updates for the Quality Payment Program (QPP) program. To date,  the Centers for Medicare & Medicaid Services (CMS) has issued many changes. The 2019 MIPS reporting requirement had an extended deadline and options for hardship exemptions. The 2020 MSSP program reporting period had many changes in both of the interim final rule with comment periods (IFCs) issued by  CMS, at the end of March and the end of April. CMS has also added a COVID-19 improvement activity to the 2020 program, that provides full credit for the Improvement Activity category for MIPS, if an individual or 50% of a group (TIN) participates in clinical trial reporting. No changes to the reporting window or other parameters of the program have been issued.