Summary of MIPS 2021 changes
Answers in Practice
By Faiza Wasif, MPH, manager, practice management, February 1, 2021
Each month DermWorld tackles issues “in practice” for dermatologists. This month Faiza Wasif, MPH, the Academy’s Practice Management manager, offers a summary of MIPS changes in 2021.
CMS released the final Quality Payment Program (QPP) Rule on Dec. 1, 2020, outlining new requirements for the 2021 Merit-based Incentive Payment System (MIPS). Below is a summary of the changes that physicians should expect.
Payment adjustment
The penalty for not participating in 2021 will remain 9% as required by law. See the full program timeline below.
MIPS program timeline
Eligibility criteria
The low-volume exemptions for participation in MIPS remain the same as 2020:
Bill ≤ $90K in Part B allowed charges for covered professional services, OR
Provide care to ≤ 200 Part B enrolled beneficiaries, OR
Provide ≤ 200 covered professional services under the Medicare Physician Fee Schedule
The voluntary opt-in option remains, allowing some clinicians, who otherwise would have been excluded under the low-volume threshold, the option to participate in MIPS. Eligible clinicians or groups will be able to opt in if they meet or exceed at least one or two, but not all three, of the low-volume threshold criterion noted above.
Eligibility can still be confirmed on the QPP website in early 2021 (once updated by CMS).
Performance thresholds
The threshold to avoid the penalty has increased in 2021. The minimum score to avoid the penalty is 60 points, up from 15 points in 2020. However, the minimum score to achieve the maximum incentive remains at 85 points.
MIPS reporting and fee schedule
See more Academy guidance and information on MIPS.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or virtual groups. Note: As in years past, for the 2021 performance period, the virtual group election should have been made by Dec. 31, 2020. In order to participate in MIPS as a virtual group, an election must be made prior to the start of the performance period and can’t be changed once the performance period begins.
Performance categories
Two performance category weights have changed: Quality and Cost. Improvement Activities and Promoting Interoperability weights remain the same. See details below.
Quality: 40% (down 5% from 2020)
Data completeness remains at 70%
Improvement Activities: 25% (same as 2020)
Group participation threshold remains at 50% of eligible clinicians
Promoting Interoperability: 25% (same as 2020)
Cost: 20% (up 5% from 2020)
Performance periods
The performance periods also remain the same in 2021 as in 2020:
Quality: 12-month calendar year performance period
Cost: 12-month calendar year performance period
Promoting Interoperability: Consecutive 90 days minimum performance period
Improvement Activities: Consecutive 90 days minimum performance period
Small practice accommodations
All of the 2021 small-practice accommodations (15 or fewer physicians) remain the same as 2020:
Claims-based reporting allowed for the Quality category
3 points awarded per quality measure that do not meet the 70% data completeness requirement
6 bonus points added to numerator of Quality category
Hardship exemption for Promoting Interoperability category available typically in fall 2021 via an application process.
Compliance resources
Check out the Academy’s CLIA, HIPAA, and OSHA compliance guidelines.
Extreme and uncontrollable circumstances
CMS will automatically reweight the Quality, Improvement Activities, Cost, and Promoting Interoperability performance categories for MIPS-eligible clinicians who are affected by extreme and uncontrollable circumstances affecting entire regions or locales. To apply, visit the QPP site.
MIPS 2021 reporting options for small practices (15 providers or less)
EHR |
Avoiding the 9% (60 points minimum) |
Achieving the (61 – 84 points) Typically, incentive is less than 0.5% Scaling factor, the more you report, the higher your incentive |
Achieving the maximum 9% incentive (average maximum incentive in years past has been significantly less due to regulatory requirements) Scaling factor, the more you report, the higher your incentive |
Small practices will have 6 bonus points automatically added to the quality category numerator |
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Without an EHR |
Apply and be approved for an EHR exemption to reweight the PI category to quality (making the quality category 65% of the overall MIPS score) then report 5 measures that can achieve a maximum of 10 points for all eligible encounters for the full year between Jan. 1-Dec. 31, 2021 |
Apply and be approved for an EHR exemption to reweight the PI category to quality (making the quality category 65% of the overall MIPS score) then report 4 measures that can achieve a maximum of 10 points for all eligible encounters for the full year (between Jan. 1-Dec. 31, 2021) AND Attest to 1 high-weighted improvement activity such as utilizing DataDerm™ for reporting (for a minimum of 90 consecutive days between Jan. 1-Dec. 31, 2021) (64.8 points) |
Apply and be approved for an EHR exemption to reweight the PI category to quality (making the quality category 65% of the overall MIPS score) then report 6 quality measures that can achieve a maximum of 10 points for all eligible encounters for the full year (Jan. 1-Dec. 31, 2021) AND Attest to 1 high-weighted improvement activity such as utilizing DataDerm™ for reporting (for a minimum of 90 consecutive days between Jan. 1-Dec. 31, 2021) AND a bonus measure (e.g., complex patient bonus measure – 5 points) (85 points) |
With an EHR |
Report 3 quality measures that can achieve a maximum of 10 points each for all eligible encounters between AND Attest to 1 high-weighted improvement activity such as reporting through DataDerm™ (for a minimum of 90 consecutive days between AND 6 PI measures from each of the 4 objectives for all eligible encounters between (64 points) |
Report 4 quality measures that can achieve a maximum of 10 points each for all eligible encounters between Jan. 1-Dec. 31, 2021 AND Attest to 1 high-weighted improvement activity such as reporting through DataDerm™ (for a minimum of 90 consecutive days between Jan. 1- AND 6 PI measures from each of the 4 objectives for all eligible encounters between Jan. 1- (70.6 points) |
6 quality measures that can achieve a maximum of 10 points each for all eligible encounters for the full year AND Attest to 1 high-weighted improvement activity such AND 6 PI measures from each of the AND A bonus measure (85 points) |
Please note, the above reporting options are not exhaustive. There may be other permutations that can achieve points needed to avoid the penalty or get an incentive.
Also note, dermatologists may be exempt from the cost category. Therefore, the 20% cost category weight may be reweighted to the quality category for those that are classified as a dermatology specialty with Medicare. Members are encouraged to check their classification directly with Medicare to confirm.
Visit the Academy's MIPS Resource Center for more guidance and information.
