There’s Still Time to Avoid a 2021 MIPS Penalty

There are fewer than 90 days left in the year, can you still report MIPS? Yes, but it will take some work. In this blog we’ll lay out how to pull everything together so you can still manage 2021 MIPS reporting.

Avoiding a MIPS penalty can have a huge impact on your bottom line. Penalties for failing 2021 MIPS range up to 9% levied on your 2023 Part B professional service reimbursements. Penalty avoidance strategies can be split based on whether or not you are going to report the Promoting Interoperability (PI) category and whether or not you will be picked up in the Cost performance category.

Once you determine which category you fall into, use this handy guide to review your requirements.

PI: To Report or Not to Report?

If you are a small practice (15 or fewer clinicians) you can apply for a small practice hardship for PI, but only if performing the PI measures would truly be a burden.

If you are in a larger practice, you can apply for a PI hardship is extenuating circumstances created an inability to perform the PI measures. For more information, visit CMS’s hardship information page.

Will I Get Scored in 2021 MIPS Cost?

It depends. In order to be scored on Cost, you must be eligible for at least one of the 20 Cost measures. Two measures are general measures:

  • Total per Capita Cost (TPCC): this measures the overall cost of care delivered to a patient with a focus on the primary care they receive from their provider(s). The measure is a payment-standardized, risk-adjusted, and specialty-adjusted measure.
    • 56 specialties and subspecialties are excluded from this measure, including ophthalmology, dermatology, and orthopedic surgery. For a full list, see the CMS TPCC codes spreadsheet, Eligible_Clinicians tab.
    • If you are group reporting and have PAs, NPs, CRNAs, or other clinicians eligible for TPCC, your group will be scored on this measure.
  • Medicare-Spending per Beneficiary (MSPB): this is measures cost related to inpatient care. If neither you nor anyone else in your group (if group reporting) provides inpatient care, you should not be scored on this measure.

The remaining 18 measures are episode-based Cost measures that measure costs related to specific episodes of care. For example, one of these is the Cataract episode-based cost measure. This is the only ophthalmic cost measure.

If you meet the criteria to be scored on any of the 20 Cost measures, Cost will comprise 20% of your MIPS Final Score.

If you are not eligible for any of the Cost measures, your Cost category weight will be redistributed to Quality. In 2021, ophthalmology-only practices that don’t perform cataract will be excluded from Cost, as will outpatient dermatology-only practices without NPs or PAs.

How Can I Report Quality?

If I Have an EHR?

You can report electronic clinical quality measures using EHR data. Contact your EHR to find out more.

If I Do Not Have an EHR?

This is a tricky question to answer. If you have not already registered for a clinical data registry, the deadline to register for your specialty-specific registry may have already passed. Check with your specialty society to find out if you can still register and what steps you can take to make manual Quality reporting easier.

Next Steps

  • Share this information with your practice colleagues.
  • Contact your Client Success Manager if you have any questions.
  • If you’re not a MarsdenAdvisors client and you want hands-on, personalized assistance, contact us and we will have your back.

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