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MIPS 2021: What you need to know from the CMS 2021 Proposed Rule

*Please note: CMS released the 2021 Final Rule on December 1, 2020. This post will be updated soon to reflect changes finalized in the rule. You’re invited to review Dr. Mingle’s final rule webinar here *

CMS released the 2021 Physician Fee Schedule Proposed Rule which impacts MIPS, APMs, and the Quality Payment Program. You’re encouraged to submit comments to CMS by October 5, 2020. The 2021 Final Rule will be released in late 2020, typically November or December.

Despite the global pandemic and relief granted in March 2020 for 2019 MIPS reporting requirements, the rule has minimal changes related to COVID-19 proposed for MIPS and the QPP. The quality program here to stay. Let’s review the major proposed changes. You can also watch Dr. Mingle’s webinar below.

Important MIPS Changes

For MIPS, there are no major proposed changes for MIPS requirements, but the program continues to get harder. The performance threshold required to avoid a penalty increases to 50, up from 45. The additional performance threshold remains at 85. The category weighting has Quality reduced to 40% and Cost increased to 20% with Improvement Activities (IA) remaining at 15% and Promoting Interoperability remaining at 25%. CMS has also proposed to use 2021 data to calculate benchmarks for 2021 submission; this departure is because CMS anticipates data to be skewed by the COVID-19 pandemic. If this moves forward, it would be challenging to estimate scores in advance. We’ll be tracking this proposal so we understand how to best guide our clients to optimize their scores and know what they need to aim for. As always, there are some proposed measure and scoring changes that our clients can rest assured our team will be watching to provide the best guidance.

Proposed Sunset of Web Interface Mechanism

For groups and virtual groups of 25 or more clinicians, a major change is the proposed sunset of the CMS web interface submission method. This impacts larger groups who participate in MIPS and APMs, especially the Medicare Shared Savings Program (MSSP). The rationale cited in the rule is CMS data indicating a 45% reduction in edibility to use the mechanism and a 40% reduction in utilization. We’re watching this proposal closely since it’s a widely used mechanism and would have a big impact on MIPS and APM participants. If the proposal moves ahead, groups will need to participate in MIPS or the new APM Performance Pathway via another mechanism including Qualified Registry or EHR.

Important APM Changes: New APM Performance Pathway

The proposed APM Performance Pathway (APP) would become the default option for many APM participants. The pathway proposes to shrink the number of measures for APMs down to 6: CAHPS for MIPS, “Diabetes: Hemoglobin A1c Poor Control,” “Preventive Care and Screening: Screening for Depression and Follow-up Plan,” “Controlling High Blood Pressure,” “Hospital-Wide, 30-day, All-Cause Unplanned Readmission Rate for MIPS Eligible Clinician Groups,” and “Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOs.” There are only three measures for submission, two administrative claims measures, and the usual CAHPS survey measure.  We’re encouraged by this new pathway because it streamlines and reduces the burden of submission, allowing organizations to move beyond just reporting and focus on improving outcomes.

Watch our webinar presented by Dr. Dan Mingle

Dive into the details of the 2021 Proposed Rule by watching this webinar originally presented by Dr. Mingle on August 19, 2020. You’ll gain an understanding of each of the major changes as well as get a preview of the proposed scoring and measure changes.

Download the Slides

Your opportunity to comment on the 2021 Proposed Rule

CMS considers feedback from participants while finalizing the rule. We encourage you to take this opportunity to share your feedback about the program. Here are the instructions.

How to submit a comment on the proposed rule:

  1. Visit
  2. Search for “CMS-1734-P”
  3. Select “Comment Now”
  4. Follow instructions to submit your comments

You may also click here to be taken to the comment section for the 2021 Proposed Rule.

What’s next?

After you submit your comment, stay tuned for the release of the 2021 Final Rule later this year, typically late November, or December.

You don’t need to wait until the final rule to understand how your organization needs to prepare for 2021 and beyond. Talk with a Mingle expert today to learn more about how we guide you to success with MIPS and the Quality Payment Program in the transition to value-based care.


2021 Final Rule Webinar

Dr. Mingle reviews changes to MIPS and the QPP as outlined in the 2021 Final Rule.

Watch Now!
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