Daily Practice

MIPS 2021

Covid-19 2020 Performance Year Flexibilities

On February 25, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that, in response to the ongoing COVID-19 public health emergency (PHE), it will hold MIPS eligible clinicians harmless from MIPS penalties due to the ongoing COVID-19 public health emergency (PHE). Read more details related to CMS' 2020 flexibilities.

2021 is the fifth year for the Quality Payment Program (QPP). Many radiation oncologists will continue to participate in the Merit-based Incentive Payment System (MIPS) even with the pending radiation oncology-specific Advanced Alternative Payment Model (RO-Model). Based on an eligible clinician’s performance in four categories in 2021, their 2023 Medicare Part B reimbursement will be impacted.

In preparation for MIPS, you need to answer the following questions:

  • What’s new this year?
  • Am I eligible?
  • How can I participate in 2021?
  • How can I submit the data to CMS?
  • Are there any bonuses?
New in 2021
Data Submission

Performance Categories

An eligible clinician or group’s overall payment adjustment is based on the Composite Performance Score (CPS). For 2021, the CPS score is based on four performance categories: Quality, Promoting Interoperability, Improvement Activities and Cost. There are specific circumstances where a practice may not qualify for a certain performance category.  

Star_Quality The Quality performance category typically comprises 40 percent of the CPS. Six quality measures are required unless your practice chooses to report the radiation oncology measure set. Data completeness rules for 2021 require a full year of reporting and at least 70 percent of patients that meet the measure’s denominator criteria, regardless of payer, with a minimum of 20 cases.
Computer_ACI The Promoting Interoperability (PI) performance category comprises 25 percent of the CPS. Hospital-based clinicians are exempt from this category and non-hospital based clinicians can apply for a hardship exemption based on certain criteria. An exemption or hardship reduces the PI category to zero and increases the Quality category weight. All reporting practices must utilize 2015 CEHRT.
Checklist_IA The Improvement Activities (IA) performance category comprises 15 percent of the CPS. Activities are weighted as medium, worth 10 points, or high, worth 20 points. Clinicians must complete activities for at least 90 consecutive days. The number of activities/points needed depends on practice location and size. RO-ILS and APEx can help satisfy the IA category requirements.
Money_Cost The Cost performance category comprises 20 percent of final score in 2021. There are currently two cost measures in the performance category: Medicare Spending Per Beneficiary (MSPB) and Total Per Capita Cost (TPCC). Providers do not report data, as CMS will use administrative claims to attribute patients and costs to providers. If CMS cannot calculate a cost score for a physician/group, then the Cost category is reduced to zero.