You May Need to Participate in MIPS Next Year

Under federal law, Qualifying Alternative Payment Model (APM) Participant (QP) thresholds are increasing beginning on January 1, 2021. If you were a QP for the 2020 performance year, you may not necessarily receive QP status for the 2021 performance year. Depending on your status in 2021, you may be required to participate in the Merit-based Incentive Payment System (MIPS) even if you haven’t in previous years.

As a reminder, if you qualify as a QP, you may be eligible for the 5% APM incentive payment and be exempt from participating in MIPS.

The Centers for Medicare & Medicaid Services (CMS) has posted a 2021 QP Quick Start Guide and 2021 MIPS Eligibility Decision Tree to provide more information on QP status and to help clinicians understand if they will need to participate in the MIPS.

What are the Thresholds for 2021?

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.

If you qualify as a Partial QP, you will be able to choose whether or not you want to participate in MIPS, but you will not be eligible for the 5% incentive payment.

How do I know if I am a QP 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.

How do I know if I’m required to participate in MIPS in 2021?

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.

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About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).