Requirement Analysis of QPP MIPS 2021

QPP MIPS 2020 is officially over, and MIPS eligible clinicians such as Anesthesiologist, Cardiologists, Dermatologists, and others, can get started on the MIPS 2021.

There is no hurry in this matter, but it is better to comprehend the program. It will help MIPS Qualified Registries to see what they can offer to their clients. Moreover, clinicians can align their efforts as per the value-based incentive program requirements.

What does the Final Rule MIPS 2021 Says?

The QPP MIPS 2021 holds many levels, and to perform well as per the criteria, we should know about all the aspects.

• MIPS Score Threshold

• Performance categories weights

• Minimum performance thresholds

• APM scoring requirements

• Hierarchy of MIPS 2021 scores

In this article, we would briefly go through each aspect to get grip on our MIPS 2021 strategies. Let’s get into it.

MIPS Score 2021

We have observed four significant changes for MIPS 2021 reporting. The performance threshold and category weights are changed. However, for this year, the corona pandemic has played a major role in administrating changes.

Thus, the scoring hierarchy will reflect on the quality. It is also to note that CMS (Centers for Medicare and Medicaid Services) has withdrawn the APM scoring thresholds.

An Insight into Performance Thresholds

Minimum Performance Threshold

In MIPS 2021, the performance threshold is set to be at sixty points. It means that eligible clinicians now have to score at least sixty to avoid penalties. Moreover, if they want to earn MIPS incentives, they must meet at least this performance threshold.

CMS suggested setting points at fifty points at first. However, after analyzing the 2019 MIPS data, they realized that clinicians could manage the performance threshold of sixty points easily.

Exceptional Performance Threshold

The threshold for exceptional performance does not change in 2021. It remained the same in 2020. 

Clinicians must achieve eighty-five points in order to get additional MIPS incentives and qualifications of a $500 million pool.  The more points you have, the more incentives you can get.

MIPS 2021 Category Weights

There are different MIPS reporting weights for different reporting frameworks. However, with MIPS 2021, we have the following percentages for the following changes.

For all eligible individuals, groups, and virtual groups, the performance weighs as follows.

• Quality category: 40%

• Promoting Interoperability (PI): 25%

• Improvement Activities (IA): 15%

• Cost category: 20%

We observe that the cost category has increased, and The quality category has decreased since last year. Whereas, PI and IA remained the same.

It is expected that in 2022, CMS would balance both categories (Cost and Quality) at 30%.

MIPS 2021 Scoring Hierarchy

The hierarchy will give an idea of what MIPS incentives to expect from eligible clinicians.

Clinicians must have an idea of what to expect in MIPS incentives in 2023.

There are four methods to participate in MIPS 2021 reporting as an individual, group, virtual group, and APM entity.

The following table will give you an idea of what we want to suggest here.

MIPS APM Participation	Participation Status	Participation Method	Eligibility	Participation Level
No	MIPS Participant	Standard	Yes	Individual, Group, Virtual Group
Yes	MIPS APM Participation	Standard	Yes	Individual, Group, Virtual Group*, APM Entity
		APP

 MIPS 2021 Payment Adjustments

For the performance of the year 2021, the MIPS payment adjustment is set to be at nine percent, which can be from -9 to +9. 

In a real-time scenario, the adjustments are lesser than the actual 9%. CMS suggests that it can be up to 6.89% for clinicians who manage to receive 100 MIPS points. Here is to remember that these points are not guaranteed but just an estimation. The actual points are based on the submitted data by the MIPS eligible clinician or the MIPS Qualified Registry on their behalf.

The ultimate goal is to achieve budget neutrality.

Requirement Analysis 

For MIPS eligible clinicians to participate and be successful in the program, one must follow the following low-threshold volume criteria. 

Clinician must:

• Have equal or more than $90K in Part B allowed charges for covered healthcare services

• Provide healthcare to equal or more than 200 Part B enrolled beneficiaries

• Provide equal or more than 200 covered professional care services under the Physician Fee Schedule (PFS)

MIPS eligible clinicians must know reporting data is inevitable, and to succeed in this program, one must start early to at least meet the standards.

From recent studies, we know that MIPS scores are above average.  Hence, the higher percentage of qualifying clinicians, the lower percentage of incentives they receive! In simple terms, the incentives are finite, and with more MIPS 2021 eligible clinicians qualifying for the bonus, lesser money will be distributed among all.