Provide Feedback on Proposed Changes to the Quality Payment Program by October 5, 2020

On August 3, the Centers for Medicare & Medicaid Services (CMS) released its proposed policies for the 2021 performance year of the Quality Payment Program via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

Note: In recognition of the 2019 Novel Coronavirus (COVID-19) public health emergency, CMS has limited annual rulemaking required by statute to focus primarily on essential policies including Medicare payment to providers.  

Submit a Formal Comment by Monday, October 5

CMS is seeking comment on a variety of proposals in the NPRM. Comments are due no later than 5 p.m. EDT, on Monday, October 5.

You must officially submit your comments in one of the following ways:

  • Electronically, through
  • Regular mail
  • Express or overnight mail

More Information on the Quality Payment Program Policies Proposed in the 2021 PFS NPRM

Key proposals for the Quality Payment Program include:

  • Increasing the complex patient bonus to a 10-point maximum for the 2020 performance year due to COVID-19
  • Postponing the implementation of the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) until 2022 instead of 2021
  • Introducing the Alternative Payment Model (APM) Performance Pathway (APP) for participants in MIPS APMs beginning in 2021
  • Increasing the performance threshold to 50 points for the 2021 performance year (10 points less than the 60-point threshold finalized for 2021 in the CY 2020 PFS Rule)
  • Decreasing the performance category weight for Quality to 40% and increasing Cost to 20%
  • Removing the CMS Web Interface as collection and submission types for reporting MIPS quality measures beginning with the 2021 performance period
  • Sunsetting the APM Scoring Standard and allowing MIPS eligible clinicians to participate in MIPS under an APM Entity beginning in 2021

For More Information

To learn more about the PFS NPRM and the Quality Payment Program proposals, review the following resources:

  • Fact Sheet – Offers an overview of the QPP proposed policies for 2021 and compares these policies to the current 2020 requirements
  • Webinar Recording – Details the QPP proposed policies for 2021, answers questions from webinar attendees, and shares information on how to comment
  • QPP COVID-19 Response Webpage – Shares information on the proposed complex patient bonus change and other flexibilities implemented in response to the public health emergency

To learn more about the Quality Payment Program, visit the Quality Payment Program website.


Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: To receive assistance more quickly, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET.

Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

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