Last Updated: Nov 12, 2020
The Centers for Medicare and Medicaid Services (CMS) recently distributed information on its Quality Payment Program (QPP), including reminders for upcoming deadlines, news on 2021 thresholds, and more. Here are the highlights.
2020 and 2021 Important Deadlines
Dec. 31, 2020 – Last day to submit 2020 Promoting Interoperability (PI) hardship exception and Extreme and Uncontrollable Circumstances (EUC) exception application. Clinicians, groups, and virtual groups who believe they are eligible for these exceptions may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories. Learn more on CMS’ website, including how to apply, here.
Note: CMS has proposed for the 2020 performance year to allow Alternative Payment Model (APM) entities to submit Extreme and Uncontrollable Circumstances applications due to COVID-19.
CMS will notify applicants via email whether their requests are approved or denied. If approved, the exception will also be added to the QPP Participation Status Tool but may not appear in the tool until the submission window opens in 2021.
Dec. 31, 2020 – 2021 virtual group election period closes. Solo practitioners and groups with 10 or fewer clinicians (including at least one MIPS eligible clinician) who wish to participate in MIPS as a virtual group for the 2021 performance year must submit their election to CMS via email.
Jan. 4, 2021 – 2020 MIPS performance data submission window opens.
March 1, 2021 – Deadline for CMS to receive 2020 claims for the Quality performance category. Claims must be received by CMS within 60 days of the end of the performance period. Deadline dates vary to submit claims to the Medicare Administrative Contractors (MACs), so check with the MACs for more specific instructions.
March 31, 2021 - Last day to submit 2020 MIPS performance year data.
2021 Thresholds in Advanced APMs
CMS also announced increasing thresholds in 2021 for qualifying participants (QP) in advanced APMs to be eligible for incentive payments in 2023.
For QP status:
- The payment amount threshold is increasing from 50% in 2020 to 75% in 2021.
- The patient count threshold is increasing from 35% in 2020 to 50% in 2021.
For Partial QP status:
- The payment amount threshold is increasing from 40% in 2020 to 50% in 2021.
- The patient count threshold is increasing from 25% in 2020 to 35% in 2021.
CMS will use three snapshot dates—March 31, June 30, and August 31, 2021, to review data to make QP determinations. CMS will make determinations approximately 4 months after the end of each snapshot date, at which point you will be able to check the Quality Payment Program Participation Status Tool for updates to your APM status.
If you qualify as a Partial QP, you will be able to choose whether to participate in MIPS, but you will not be eligible for the 5 percent incentive payment.
If you are MIPS eligible and not determined to be a QP or a Partial QP, you will be required to participate in MIPS and will receive a MIPS Final Score and payment adjustment. To learn more about MIPS, visit qpp.cms.gov.
Additional information and resources are available in the QPP Resource Library at https://qpp.cms.gov/about/resource-library.