CMS Plans to Reweight 2021 MIPS Cost Performance Category

CMS will reweight the cost performance category under the Merit-Based Incentive Payment System (MIPS) for the 2021 performance period due to the COVID-19 pandemic’s impact on clinicians and cost measures, according to an announcement RevCycleIntelligence received by email.

The cost performance category weight will change from 20 percent to 0 percent. The 20 percent will be redistributed to other performance categories, including the quality performance category, improvement activities performance category, and promoting interoperability performance category.

In November 2021, CMS applied the automatic extreme and uncontrollable circumstances (EUC) policy and reweighted the cost performance category for the 2021 performance year to 0 percent for all individual MIPS eligible clinicians.

After analyzing underlying 2021 data, the agency found similar results across measures for both group and individual clinicians. CMS said that reweighting should not depend on whether a clinician chose to report as a group or individual and decided to reweight the cost performance category for all clinicians.

Additionally, the agency said it is not confident that it could reliably calculate scores for select cost measures that would adequately capture and reflect the performance of MIPS eligible clinicians.

Most of the measures have higher observed and risk-adjusted costs at the episode level, meaning that risk adjustment does not entirely account for the differences in resource use. This would inadequately reflect the measures that are clinically proximate to respiratory disease and COVID-19, the announcement stated.

At the provider level, performance scores for most measures were not negatively affected by higher caseloads with COVID-19 diagnoses, but there are a small number of measures for which this may impact scores, CMS noted.

Instead of reweighting the cost performance category for the 2022 performance period, providers may suppress individual cost measures if the data used to calculate the score was impacted by significant changes during the performance period, the announcement added. This can help providers avoid misleading scores that incorporate inaccurate data.

The cost performance category relies on administrative claims data; therefore, clinicians do not need to take any action in response to the reweighting.

If MIPS eligible clinicians are scored on fewer than two performance categories—when one category is weighted at 100 percent or all categories are weighted at 0 percent—they will receive a final score equal to the performance threshold. This score will give them a neutral MIPS payment adjustment for the 2023 MIPS payment year.

Last year, CMS also reweighted the MIPS cost performance category for the 2020 performance year. The agency had shifted the weight from 15 percent to 0 percent because of the impacts of the pandemic.

After reweighting the cost performance category for the second year in a row, CMS acknowledged that clinicians might need more insight into their performance in this category. The agency plans to provide patient-level reports on the 2021 cost measures for which clinicians, groups, and virtual groups met the case minimum. These reports will be included in the August 2022 final performance feedback.

CMS reiterated that it would not include measure-level scoring information in performance feedback as it cannot reliably calculate accurate scores for the cost measures.

CMS created MIPS to monitor provider performance and use the results to determine future Medicare reimbursement rates. It is expected that clinicians will be incentivized to provide quality care to patients to receive MIPS scores that will generate positive payment adjustments.

However, some industry leaders have questioned whether the value-based payment system is the most efficient way to evaluate care quality.

A study from August 2021 revealed that higher MIPS quality scores were rarely associated with lower rates of hospital complications during the first year of program participation.

Additionally, a recent study found that psychiatrists had lower MIPS performance scores and received more penalties than other outpatient physicians, suggesting that the program does not accurately measure care quality among mental health providers.