The Centers for Medicare and Medicaid Services (CMS) has changed the reporting requirements for clinicians in MIPS APMs in 2021 MIPS.

In the past, eligibility and reporting for these clinicians was determined and completed at the MIPS APM Entity level. Starting in 2021, clinicians in MIPS APMs are no longer automatically scored based upon their MIPS APM's quality reporting. In addition, MIPS APM clinicians' MIPS eligibility will be determined at the individual or group level.

What This Means

This means that clinicians in MIPS APMs must report MIPS at the individual or group level unless their MIPS APM informs them that it will report for them. Even if the MIPS APM reports for its clinicians, starting this year, clinicians who separately report MIPS at the individual or group level will receive whichever score is higher.

Ways to Report

CMS has retired the APM Scoring Standard. Now clinicians in MIPS APMs can report through one of two pathways:

• Traditional MIPS (the MIPS we all know and love), or
• The APM Performance Pathway (APP)

The APP is a new pathway through which clinicians in MIPS APMs can report starting in 2021. We don't recommend this pathway for most specialists since the quality measures required are more primary care focused.

The APM Performance Pathway (APP)

Below are the 2021 reporting requirements under the APP.

Comparison of MIPS vs APP

If you are a MarsdenAdvisors client, your Client Success Manager will walk you through choosing and reporting the best option for you. Otherwise, as a general rule, we recommend traditional MIPS to specialists since you can choose specialty-specific measures and avoid having to contract with a third party to administer the CAHPS survey to your patients.

Next Steps

• Share this information with your practice colleagues.
• Contact your MarsdenAdvisors Client Success Manager if you are in a MIPS APM and have not yet chosen your reporting path.

If you have any questions on this, let us know!