Author: Tony Mira
For the last several years, Medicare has increasingly placed an emphasis on a pay-for-performance model of reimbursement. It began with various incentive programs, such as PQRS, and continues with today’s MIPS and alternative payment models (APMs). In the near future, new twists on this theme will emerge. Today’s article touches on the current and coming iterations of the Medicare quality agenda.
The new year of quality reporting brings about some changes that may feel a little uncomfortable for the anesthesia specialty. As the Quality Payment Program (QPP) progresses, it will increasingly become harder to comply; however, there may be a light at the end of the tunnel with the MIPS Value Pathways (MVPs) initiative. In this update, we will briefly review what occurred in 2020 with respect to the QPP, as well as what is required for 2021. Lastly, we will provide a glimpse of the soon-coming MVP and what that might look like for anesthesia.
What Happened with 2020?
The pandemic had massive impacts on all clinicians and facilities, but this review will outline those elements that affected the QPP and the anesthesia specialty specifically. The most substantial change adopted by the Centers for Medicare and Medicare Services (CMS) provided the automatic exception for 2019 dates of service and an optional exception for 2020 dates of service due to COVID-19. The move to eliminate the requirement for submission of 2019 dates of service limited the number of bonuses that would be available given that QPP is designed to be budget-neutral; bonuses are paid by the penalties. Lastly, the deployment of the MVP model was deferred to 2022 which we will review below.
Some have argued that the exception be automatic for 2020 as well since COVID-19 only truly affected 2020 dates of service, but the optional exception had to be applied for if interested. Additionally, 2020 adopted an increased threshold for achieving the exceptional performance to 85 points from 75 points, making any bonus collection more difficult.
What Are the Current Requirements for 2021?
Each year brings about change to the QPP and unfortunately, each year makes it more difficult to achieve a bonus, let alone compliance. The current year represents the final step towards the full implementation of the QPP under the MACRA legislation. Some of the key 2021 program requirements are discussed below.
The reporting requirement or completeness measurement stands at 70 percent of all eligible patients for the year, starting on January 15. This is due to the late delivery of the approved measures to the registries, and they have deferred the start date by two weeks. We will be calculating all reports starting on January 1, in the event there is an update by CMS mid-year.
Second to the reporting completeness measure is the increase in the total MIPS points required to avoid a penalty, which is up to 60 MIPS points from 45 points in 2020. This represents a sizeable increase and will even further play into a practice strategy for quality submissions for 2021.
One of the factors that is also affected by the updated requirements for 2021 is the rebalancing of each category in MIPS. The Quality category is now worth 40 percent (down from 45 percent in 2020), Cost is now 20 percent (up from 15 percent in 2020), Promoting Interoperability stays at 25 percent and Improvement Activities remain at 15 percent. Most anesthesia providers are exempted from the Promoting Interoperability measures, which will translate into an adjusted Quality category weighting of 65 percent of the total score. This Quality score will continue to degrade into the 2022 reporting year, putting emphasis on the Cost category, which you can’t easily affect.
Lastly, and the most troubling, is the increase of the penalty percentage in 2021. MIPS-eligible clinicians who fail to meet the requirements set forth above will receive a -9 percent (up from 7 percent in 2020) penalty adjustment on their 2023 Medicare Part B payments for covered services.
In order to summarize some of the key changes that are likely to affect our clients, here is a quick review:
- Must report 70 percent of all eligible patients for the year
- Must achieve more than 60 points to avoid a penalty
- Increase in penalty of 9 percent of Medicare covered services
Will the QPP MVP be Anesthesia’s MVP?
As previously mentioned, MVP, in the context of the QPP, stands for a MIPS Value Pathway, which is CMS’ effort to reduce the burden on providers when complying with the overall program. Originally slated to be deployed in 2021, CMS decided to move the introduction of this model to 2022, and they have provided preliminary guidance that this model will not initially be required.
In essence, the MVP is designed to align all categories of the QPP (cost, promoting interoperability, improvement activities and quality) into a streamlined model for better reporting and relevance for specialties. This has yet to be defined for anesthesia; but, to better explain what CMS is trying to do, the agency included an example for a surgeon, available at https://qpp.cms.gov/mips/mips-value-pathways).
Rather than having to meet all the requirements across each category individually, an MVP will have specific and required metrics included from different categories to submit as a bundle. This could potentially lessen the reporting and submission burden for anesthesia, given that most practices are already compliant with all the quality measures available and report several improvement activities. These MVPs are to be defined and approved in 2021 for use in 2022; and, when they have been listed and approved, we will be sure to include an update for community comment.