Quality Payment Program: The proposed updates slated for 2021
BY JENIANN A. YI, MD, AND ASHLEY K. VAVRA, MD
The COVID-19 pandemic’s impact on surgery and medicine continues, prompting the Centers for Medicare and Medicaid Services (CMS) to propose changes in year five of the CMS Quality Payment Program (QPP). These changes were to take effect Jan. 1, 2021.
THE SOCIETY FOR VASCULAR SURGERY (SVS) will compose a comment letter in response to the proposed changes, advocating on behalf of its members.
CMS released its proposed updates for year five in August. The rule acknowledges the impact of COVID-19 and the need for more gradual implementation of originally planned changes.
The QPP was created following passage of the 2015 Medicare Access and Children’s Health Insurance Program Reauthorization Act (MACRA). The legislation repealed the Medicare sustainable growth rate formula and created the QPP. The program is a value-based reimbursement model, which requires Medicare providers to participate in the Merit Based Incentive Payment System (MIPS) or an Alternative Payment Model (APM) to avoid penalties.
In the wake of the ongoing pandemic, CMS’ proposed rule delays introduction of two new participation pathways, the MIPS Value Pathways (MVP) and the APM Performance Pathway (APP). CMS instead proposes changes to guiding principles and development criteria for MVPs and changes to the APP option that will help facilitate ultimate transition. The CMS web interface will be phased out in 2021 as part of the transition towards these new pathways; organizations reporting through this mechanism should identify another method.
The proposed rule also would modify performance thresholds. The minimum performance threshold to avoid a penalty is proposed to increase from 45 to 50 points, 10 points less than anticipated.
The threshold for exceptional performance remains at 85 points. The Quality performance category would be weighted at 40% (decreased by 5%), while the Cost performance category’s weight is proposed at 20% (increased 5%).
These changes reflect the requirement for equal weighting of those two performance categories at 30% by the 2022 performance period. The Promoting Interoperability (PI) (25%) and Improvement Activities (IA) (15%) performance categories have remained unchanged in weight since the 2020 proposed rule. Maximum negative and positive payment adjustments remain at -9 and 9%, respectively; Medicare physicians who do not perform adequately in an APM or MIPS in 2021 will be subject to as much as a 9% reimbursement penalty in 2023.
The Cost category was primarily impacted by the addition of measures related to telehealth services. Minor changes are proposed for the PI and IA categories, primarily involving the pathways for nominating a new measure and/or activity.
Given the disruption in care from COVID-19, Quality measures will be scored by performance period, not historical benchmarks. In terms of scoring flexibility, there will also be an expanded list of reasons impacting quality measure performance as well as a revised policy regarding truncation of the performance period to nine months or suppression of the measure if nine months of data is unavailable. Additionally, in light of the COVID-19 emergency, CMS is using the Extreme and Uncontrollable Circumstances policy to allow participants to request a reweighting of one or more MIPS performance for the 2020 performance year.
The SVS will compose a comment letter in response to the proposed changes, advocating on behalf of its members to maintain the weighting of the Quality and Cost categories and the minimum performance threshold at the same level as performance year four, in order to minimize additional burden on providers during the COVID-19 pandemic.
Jeniann A. Yi and Ashley K. Vavra are members of the SVS Quality and Performance Measures Committee.