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November 2021 Quest Details

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2023 and Beyond: QPP Final Rule Highlights—Additional Finalized Policies

The following updates were also included in the Physician Fee Schedule (PFS) Final Rule and affect future years of the Quality Payment Program (QPP):

  • Finalizing 7 Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) that will be available, beginning with the 2023 performance year.
  • Providing a description of the registration process and timeline for MVPs and subgroup registration, beginning with the 2023 performance year.

For More Information

To learn more about the calendar year (CY) 2022 PFS Final Rule and all of the 2022 QPP finalized policies, please review the following resources:

  • Press Release: Provides additional details regarding the announcement.
  • QPP 2022 Final Rule Resources ZIP File: Contains the following:
    • Overview Fact Sheet: Offers an overview of the QPP Final Rule policies for the 2022 performance year.
    • Policies Comparison Table: Compares the final 2022 performance year policies to the requirements for the 2021 performance year.
    • MVP Policies Table: Provides an overview of the policies for implementation of MVPs beginning in the 2023 performance year.
    • Frequently Asked Questions (FAQs): Addresses the FAQs for the 2022 QPP Final Rule policies.

 

CMS Publishes 2022 PFS Final Rule for the Quality Payment Program

CMS published the CY 2022 Medicare PFS Final Rule, which includes the final policies for the 2022 performance year of the QPP. The rule affects traditional MIPS, MIPS Value Pathways (MVPs), the APM Performance Pathway (APP), Advanced APMs, and the Medicare Shared Savings Program (Shared Savings Program).

2022: QPP Final Rule Highlights

  • Revising the definition of a MIPS-eligible clinician to include social workers and certified nurse mid-wives.
  • Setting the MIPS performance threshold at 75 points and the exceptional performance threshold at 89 points.
  • Weighting the cost and quality performance categories equally (as statutorily required) at 30%.
  • Extending the CMS Web Interface as a collection type and submission type in traditional MIPS for registered groups, virtual groups, and APM Entities for the 2022 performance year only.
  • Finalizing a longer transition for electronic clinical quality measures (eCQMs)/MIPS clinical quality measures (CQMs) measure reporting for Shared Savings Program Accountable Care Organizations (ACOs) by extending the CMS Web Interface as an option for 3 years (through the 2024 performance year).

2023 and Beyond: QPP Final Rule Highlights—Additional Finalized Policies

The following updates were also included in the PFS Final Rule and affect future years of the QPP:

  • Finalizing 7 MVPs that will be available, beginning with the 2023 performance year.
  • Providing a description of the registration process and timeline for MVP and subgroup registration, beginning with the 2023 performance year.

For More Information

To learn more about the CY2022 PFS Final Rule and all of the 2022 QPP finalized policies, please review the following resources:

  • Press Release: Provides additional details regarding today’s announcement.
  • QPP 2022 Final Rule Resources ZIP File: Contains the following:
    • Overview Fact Sheet: Offers an overview of the QPP Final Rule policies for the 2022 performance year.
    • Policies Comparison Table: Compares the final 2022 performance year policies to the requirements for the 2021 performance year.
    • MVP Policies Table: Provides an overview of the policies for implementation of MVPs beginning in the 2023 performance year.
    • Frequently Asked Questions (FAQs): Addresses the FAQs for the 2022 QPP Final Rule policies.
       

 

2021 MIPS Automatic Extreme and Uncontrollable Circumstances (EUC) Policy Applied in Response to COVID-19 Public Health Emergency

The automatic EUC policy only applies to MIPS-eligible clinicians who are eligible to participate in MIPS as individuals. The automatic EUC policy doesn’t apply to groups, virtual groups, or Alternative Payment Model (APM) Entities.

Learn what this means for you below. 

MIPS-eligible clinicians who are eligible to participate in MIPS as individuals

You do not need to take any action to have the automatic EUC policy applied to you. You will be automatically identified and will have all 4 MIPS performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless you 1) submit data in 2 or more performance categories, or 2) have a higher final score from group or APM Entity participation. 

Small practices reporting Medicare Part B claims measures

Under current policies, CMS automatically calculates a quality score from Medicare Part B claims measures at the individual and group level.

  • Clinicians in small practices that report Medicare Part B claims measures who are only eligible to participate in MIPS as part of a group are not covered by the automatic EUC policy and will receive the group’s final score. (To identify these clinicians, sign in to qpp.cms.gov, navigate to the “Eligibility & Reporting” page and click “View Clinician Eligibility." Clinicians who are only eligible to participate as part of a group will have a green check mark next to “Group”; there will not be a green check mark next to “Individual.")
  • Some small practices may not be aware of the implications of their PY 2021 claims reporting due to some of the policies CMS introduced at the onset of the COVID-19 public health emergency (PHE).
  • As a result, these small practices may wish to request performance category reweighting on behalf of the group through the PY2021 EUC Exception Application, citing COVID-19 as the triggering event.
  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation.

Groups

The automatic EUC policy does not apply to groups. You do not need to take any further action if you are not able to submit data for the 2021 performance year. Group participation is optional (specific guidance for small practices noted above), and your individually eligible MIPS-eligible clinicians qualify for the automatic EUC policy if you do not report at the group-level on their behalf. (If you submit data at the group level on behalf of your MIPS-eligible clinicians, the group will receive a MIPS final score based on the data submitted.) Your MIPS-eligible clinicians will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories, or 2) they have a higher final score from group or APM Entity participation. 

Virtual Groups

MIPS-eligible clinicians in a virtual group will receive a payment adjustment based on the virtual group’s final score, even if no data is submitted. (When no data is submitted for the virtual group, the MIPS-eligible clinicians in the virtual group could receive the maximum negative payment adjustment of -9% in the 2023 payment year.)

  • If you are unable to submit data for the 2021 performance year as a result of the ongoing COVID-19 PHE, you can submit a PY2021 EUC Exception Application on behalf of the virtual group, citing COVID-19, to request reweighting for all 4 performance categories.
  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

APM Entities

The automatic EUC policy does not apply to APM Entities. You do not need to take any action if you are not able to submit data for the 2021 performance year. APM Entity participation is optional (specific guidance for small practices noted above), and your individually eligible MIPS-eligible clinicians will have the automatic EUC policy applied to them if you do not report at the APM-Entity level on their behalf. (If you submit data at the APM-Entity level on behalf of your MIPS-eligible clinicians, the APM Entity will receive a MIPS final score based on data submitted.) Your MIPS-eligible clinicians will have all 4 performance categories reweighted to 0% and receive a neutral payment adjustment for the 2023 MIPS payment year unless 1) they submit data in 2 or more performance categories, or 2) they have a higher final score from group or APM Entity participation. 

If your APM Entity would like to request performance category reweighting for the 2021 performance year, you must submit an EUC application.

  • PY2021 EUC Exception Applications can be submitted by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

Medicare Shared Savings Program ACOs

The MIPS Automatic EUC policy does not apply to Shared Savings Program Accountable Care Organizations (ACOs). ACOs can submit a PY2021 EUC Exception Application on behalf of its MIPS-eligible clinicians if they are unable to report via the Alternative Payment Model (APM) Performance Pathway (APP). To submit a PY2021 EUC Exception Application, ACOs must demonstrate that greater than 75% of its MIPS-eligible clinicians would be eligible for reweighting the Promoting Interoperability performance category. ACOs can submit PY2021 EUC Exception Applications by signing in to qpp.cms.gov and clicking Exception Applications on the left-hand navigation through December 31, 2021.

Note: The Shared Savings Program Quality EUC policy for determining shared savings and losses applies to all Shared Savings Program ACOs for performance year 2021. CMS considers all ACOs to be affected by the COVID-19 PHE and the Shared Savings Program EUC policy applies for PY2021. ACOs that are able to report quality data via the APP and meet MIPS data completeness and case minimum requirements will receive the higher of their ACO quality score or the 30th percentile MIPS quality performance category score. ACOs that are unable to report quality data via the APP and meet the MIPS quality data completeness and case minimum requirements, will have their quality score set equal to the 30th percentile MIPS quality performance category score.

Additional Resources

For more information, please see the QPP COVID-19 Response webpage on the QPP website. You can contact the QPP at 1.866.288.8292 (TRS: 711), Monday through Friday, 8 a.m.-8 p.m. ET or by email at: QPP@cms.hhs.gov.