CMS to Reweight MIPS Cost Performance Category for 2020

May 25, 2021 - CMS announced it will be reweighting the cost performance category under the Merit-Based Incentive Payment System (MIPS) from 15 percent to zero percent for the 2020 performance period to provide additional COVID-19 relief and account for the lack of reliable data.

The MIPS cost performance category was original weighted at 15 percent. Now, those points will be redistributed to other categories and will impact reimbursements paid out to eligible clinicians in 2022.

“Our analysis of the underlying data for the 2020 performance year, in comparison to prior years’ data, shows that the volume of data available to calculate the scores for the cost measures has significantly decreased overall,” CMS stated in a Quality Payment Program email late last week.

“As a result, we do not believe we can reliably calculate scores for the cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians,” the agency stated.

The pandemic had a significant impact on healthcare visits and primary care visits in particular, with many practices struggling to bounce back over a year later. CMS points out that the lack of service utilization data in the 2020 reporting period could lead to inaccurate or skewed results.

“A significant decrease in service utilization in 2020 demonstrates cost measures may not accurately characterize patient risk due to the lack of diagnosis information in the lookback periods used for risk adjustment,” the email stated.

In addition, “episodes with COVID-19 diagnoses generally have higher observed and risk-adjusted costs, indicating COVID-19 impacted service utilization and wasn’t sufficiently accounted for through risk adjustment,” CMS stated. Compared to prior years, significantly fewer clinicians met 2020 cost measure case minimums.

Because of the extenuating circumstances, CMS decided that calculating scores based on inconsistent cost measures and unreliable data would not accurately and fairly reflect clinician performance.

Under normal circumstances, CMS uses four categories to evaluate performance and determine payment rates under MIPS—quality, promoting interoperability, improvement activities, and cost. Clinicians can apply to be covered under the Extreme and Uncontrollable Circumstances (EUC) Exception, which is applicable if they are exposed to an emergency, such as COVID-19.

Prior to this announcement, CMS had automatically applied the exception policy to all MIPS clinicians reporting as individuals during the 2020 performance period. Because of this, all four categories were reweighted to zero percent for individual MIPS clinicians, unless they were able to submit data for two or more categories, CMS’ Quality Payment Program website states.

The announcement explained that even clinicians who were not covered or did not apply to be covered under the EUC policy will still receive the weighting adjustment for the cost performance category. No clinician action is required to receive the adjustment, since the cost category uses administrative claims data.

CMS also noted that in the event a MIPS clinician is scored on less than two of the four performance categories, their final score will be equivalent to the performance threshold and they will receive a neutral MIPS payment adjustment in 2022.

Debates over reporting on quality measures under MIPS have led to many physicians raising concerns in recent years. In 2018, experts called for MIPS to be repealed because it relies on self-reported quality measures, allowing clinicians to select which quality measures they want to report on. Since then, CMS has enacted changes within MIPS to combat this issue, including MIPS Value Pathways (MVPs). While cost measures have not been at the forefront of these concerns, this announcement ensures that unreliable cost data is not factored into 2022 MIPS payments.