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No Cost Scores for 2021 MIPS!

CMS Hardship MIPS 2021 cost COVID-19

On April 25, 2022, the Centers for Medicare and Medicaid Services (CMS) announced that they will reweight the Cost performance category from 20% to 0% for the 2021 MIPS performance period for all MIPS eligible clinicians, regardless of participation as an individual, group, virtual group, or APM Entity.  

This announcement comes in recognition of the impact of the COVID-19 public health emergency on cost data in 2021. 

Cost was already reweighted to 0% for all individual MIPS eligible clinicians, even if data were submitted for other performance categories, due to the automatic extreme and uncontrollable circumstances (EUC) policy. CMS's analysis of the underlying data for the 2021 performance period shows similar results at the group- and individual-level across measures. As a result, CMS believes that reweighting shouldn’t depend on whether you choose to report as a group or individual.

Specifically, CMS states that they do not believe they can reliably calculate 2021 Cost scores because of the following:

  • Most measures have higher observed and risk-adjusted costs at the episode-level. This indicates that risk adjustment at the episode-level doesn’t entirely account for differences in resource use, particularly for broader measures or measures that are clinically proximate to respiratory disease and COVID-19.
  • There’s less of an effect at the provider-level for most measures where testing shows that scores don’t appear to be adversely impacted by higher case-loads of episodes with a recent or concurrent COVID-19 diagnosis. However, there are a small number of measures where scores may be adversely affected by the volume of episodes with a COVID-19 diagnosis.      

Important Notes:

  • If you submit data on 1 or fewer MIPS categories, CMS will assign you a 2021 MIPS score equal to the threshold to avoid a penalty.
  • The new category weights and reweighting options for 2021 MIPS are shown below

New 2021 MIPS Category Weight and Reweights

Next Steps

  • Share this information with your practice colleagues.
  • Subscribe to our newsletter to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • Contact your MarsdenAdvisors Client Success Manager if you have any questions.
  • If you are not a MarsdenAdvisors client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.


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

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Senior Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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