KENTUCKY REGIONAL EXTENSION CENTER

From CMS:

CMS Reweighting 2021 MIPS Cost Performance Category

The Centers for Medicare & Medicaid Services (CMS) recognizes the impact that the COVID-19 pandemic public health emergency (PHE) continued to have on clinicians and the services they provided in the 2021 performance period.

Due to COVID-19’s impact on cost measures, we’re reweighting the cost performance category from 20% to 0% for the 2021 performance period. The 20% cost performance category weight will be redistributed to other performance categories in accordance with § 414.1380(c)(2)(ii)(E). Please see the table below for reweighting scenarios.

Why CMS is Reweighting the MIPS Cost Performance Category for 2021

Cost was already reweighted to 0% for all individual MIPS eligible clinicians, even if data were submitted for other performance categories, due to the automatic extreme and uncontrollable circumstances (EUC) policies under § 414.1380(c)(2)(i)(A)(6) and § 414.1380(c)(2)(i)(C). Our analysis of the underlying data for the 2021 performance period shows similar results at the group- and individual-level across measures. As a result, we believe that reweighting shouldn’t depend on whether you choose to report as a group or individual.

Given these circumstances and in accordance with § 414.1380(c)(2), we’ll assign a weight of 0% to the cost performance category for the 2021 performance period and redistribute the prescribed weight of 20% to another performance category or categories.

Specifically, we don’t believe we can reliably calculate scores for some of the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians based on the following reasons, as shown by our analysis of the cost performance category data for the 2021 performance period:

• Most measures have higher observed and risk-adjusted costs at the episode-level. This indicates that risk adjustment at the episode-level doesn’t entirely account for differences in resource use, particularly for broader measures or measures that are clinically proximate to respiratory disease and COVID-19.

• There’s less of an effect at the provider-level for most measures where testing shows that scores don’t appear to be adversely impacted by higher case-loads of episodes with a recent or concurrent COVID-19 diagnosis. However, there are a small number of measures where scores may be adversely affected by the volume of episodes with a COVID-19 diagnosis.

Please note that starting with the 2022 performance period, instead of reweighting the entire cost performance category, individual cost measures can be suppressed if the data used to calculate the score was impacted by significant changes during the performance period, such that calculating the cost measure would lead to misleading or inaccurate results. This provision allowing greater flexibility was finalized in the CY 2022 Physician Fee Schedule Final Rule.

Clinicians don’t need to take any action as a result of this decision because the cost performance category relies on administrative claims data.

MIPS Performance Category Weight Redistribution Policies Finalized for the 2021 Performance Period

The table below* illustrates the MIPS performance category weights and reweighting policies that apply to MIPS eligible clinicians, groups and virtual groups in the 2021 performance period.

*This table can be found at § 414.1380(c)(2)(ii)(E).

This reweighting of the cost performance category applies in addition to the extreme and uncontrollable circumstances (EUC) policies under § 414.1380(c)(2)(i)(A)(6) and § 414.1380(c)(2)(i)(C).

• Cost was already reweighted to 0% for all individual MIPS eligible clinicians, even if data were submitted for other performance categories, due to the automatic EUC policy.
• Cost will now be reweighted to 0% for all groups and virtual groups, even if they didn’t request reweighting through an EUC exception application.

As a reminder, under § 414.1380(c), if a MIPS eligible clinician is scored on fewer than 2 performance categories (meaning 1 performance category is weighted at 100% or all performance categories are weighted at 0%), they’ll receive a final score equal to the performance threshold and a neutral MIPS payment adjustment for the 2023 MIPS payment year.

Cost Data in Performance Feedback for 2021

We recognize that this is the second year that we’ve had to reweight the cost performance category due to COVID-19, and that clinicians need more insight into and familiarity with their performance in this category. To support this need, we’ll provide patient-level reports on the 2021 cost measures for which clinicians, groups and virtual groups met the case minimum. Patient-level reports will be available as part of the final performance feedback in August 2022.

Please note that we won’t include measure-level scoring information in performance feedback. As previously mentioned, we don’t believe we can reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians.

Questions?

Please contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours – before 10 a.m. and after 2 p.m. ET.
• Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Contact the expert advisors at Kentucky REC for all your QPP, MIPS, and APM questions. We’re here to help: 859-323-3090.