Quality Payment Program Updates for 2021

A Focus on Reducing Burden to Ensure Patients Get the Care They Need!

Quality Payment Program updates for 2021 are centered on adequate patient care — which is CMS' number one priority during the COVID-19 pandemic.
CMS is determined to lessen the administrative burden associated with participating in the Merit-based Incentive Payment System (MIPS) so that providers can focus on ensuring patients get the care they need during the COVID-19 public health emergency.
Thus, the following changes were made for next year and are documented in the CY2021 Physician Fee Schedule (PFS) Final Rule:

  1. The performance threshold for 2021 will be 60 points, instead of the 50 points that were previously proposed. So, the threshold is 15 points higher than the 2020 performance period threshold.
  2. Instead of in 2021, as originally planned, MIPS Value Pathways (MVPs) will be implemented in 2022.
  3. Third parties, such as Qualified Registries and Qualified Clinical Data Registries, will be under new guidance regarding remedial action, termination, and re-approval of participation. The aim is to improve the services clinicians receive from third parties and reduce reporting burdens.
  4. The complex patient bonus is raised to a 10-point maximum (from 5 points) for clinicians, groups, virtual groups, and Alternative Payment Model (APM) Entities for the 2020 performance period only. CMS brought in this policy to remove the extra task of treating complex patients during the COVID-19 public health emergency.
  5. ACOs and other APM Entities are allowed to use the Extreme and Uncontrollable Circumstances Reweighting Application to request reweighting of all MIPS performance categories, starting with the 2020 performance period. In cases where the request is approved, the APM Entity group gets a score equal to the performance threshold — even when data are submitted. While this new rule pertains to APM Entities only, the previously made policy pertains to individuals, groups, or virtual groups.
There are also other important changes to the Quality Payment Program for the 2021 performance period. They include these:

  • The termination of the CMS Web Interface is delayed until 2022. For the 2021 performance period, the CMS Web Interface will continue to be an optional, alternative collection type. But in the 2022 performance period, the CMS Web Interface for groups and virtual groups will not be available for collecting and submitting data for reporting MIPS Quality measures.
  • The Alternative Payment Model (APM) Scoring Standard is discontinued. MIPS-eligible clinicians can participate in MIPS under their APM Entity, and various APM Entities can report to MIPS on behalf of their clinicians. However, there is a new optional pathway, referred to as the Alternative Payment Model Performance Pathway, which would be accessible to anyone in MIPS APMS.

Key Updates in MIPS Performance Categories

Here are the updates in MIPS performance categories for the 2021 performance period:

  • Quality: The weighting for the Quality performance category in participants' final score will be 40%, which is lower than the 45% it had in the 2020 performance period. CMS also stated that it had gotten sufficient data for the 2019 performance period, which can be used to calculate historical benchmarks for the 2021 performance period. However, due to PHE concerns, CMS had previously proposed the use of performance period benchmarks, rather than historical benchmarks, to score Quality measures for the 2021 performance period.
  • Improvement Activities: CMS made new policies for the Annual Call for Activities, including flexibility for Agency-nominated Improvement Activities and an exception to the nomination period timeframe during a public health emergency.
  • Promoting Interoperability: CMS retained the Query of Prescription Drug Monitoring Program measure as optional. However, it increased its worth from 5 to 10 bonus points. CMS is also adding a new Health Information Exchange (HIE) Bi-Directional Exchange measure as optional, and it will be worth 40 points.
  • Cost: The weighting for the Cost performance category in participants' final score will be 20%, which is higher than the 15% it had in the 2020 performance period. Telehealth services that are directly applicable to existing episode-based cost measures and the total per capita cost (TPCC) measure have been included in the CMS' updates of existing measure specifications.

General information

Performance, under MIPS, is assessed across multiple performance categories that are used to ascertain improved quality and value in the healthcare system.
For a provider that is eligible for MIPS in 2021:

  • The provider has to provide data for the quality, improvement activities, and promoting interoperability performance categories.
  • His or her performance across the MIPS performance categories — with each assigned a specific weight — will be calculated to get the MIPS final score of 0 to 100 points.
  • The MIPS final score is what determines whether the provider would receive a negative, neutral, or positive MIPS payment adjustment.
  • The MIPS payment adjustment depends on performance during the 2021 performance year, but it is applied to payments for covered professional services that begin on January 1, 2023.


For an individual, group, virtual group, or APM Entity to meet the quality performance category requirements, they have to do one of the following:

  • Provide at least 6 MIPS quality measures for the 12-month performance period
  • Provide a defined specialty measure set.
  • Provide all 10 CMS Web Interface measures.


Medicare claims data submitted in 2021 will be used to calculate cost measure performance, so for this performance category, there are no additional requirements for data submission.

Improvement Activities

In the improvement activities performance category, providers can earn up to 40 points if they can show about 2 to 4 improvement activities. All the provider has to do to report an improvement activity is just attest to having completed it. There's no need for any data when reporting this. 
While no supporting documentation is needed when attesting to completing an improvement activity, providers must document their efforts to meet the improvement activity for 6 years following the submission. You can find the documentation guidelines for each activity in this 2021 MIPS Data Validation Criteria.

Promoting Interoperability

This performance category is concerned with 4 objectives: 
  • e-Prescribing 
  • Health Information Exchange 
  • Provider to Patient Exchange
  • Public Health and Clinical Data Exchange (HIE) 
There are 5 or 6 required measures and attestations for these objectives, but the provider can choose which measure(s) to report for the HIE measure objective.

WCH provides MIPS supporting services, including assistance in choosing the performance measures under each category and assistance in collecting and submitting data. Please, quickly contact Feruza Khaydarova, our MIPS and EHR advisor at feruzak@wchsb.com or call 718-934-6714 ext 1311.