On April 25, the Centers for Medicare & Medicaid Services (CMS) announced the reweighting of the Merit-Based Incentive Payment System (MIPS) cost performance category for 2021 performance year from 20% to 0%. In a 2020 comment letter submitted in response to the 2021 Physician Fee Schedule proposed rule, the AAMC urged the agency to reweight the cost category to 0% when cost performance is impacted due to factors that are outside the control of the physicians, such as a public health emergency (PHE). In this letter, the AAMC noted that “[p]hysicians treating COVID-19 may have patients that are more likely to have complications, admissions, and readmissions due to the COVID-19 pandemic, which may cause these physicians to receive lower scores on cost measures.” The AAMC also conveyed concern that the PHE could cause disruptions to the attribution, reliability, and validity of data used to determine the score of the cost measure.
In the April 25 announcement, the CMS mirrored these concerns, stating that the 2021 cost measures would not accurately reflect the performance of MIPS-eligible clinicians because of the impacts of the PHE. As a result, the 20% originally designated to the cost measure will be redistributed to the remaining performance categories. For the 2021 performance year (which is the 2023 payment year) the quality performance category weight is 55%, the cost performance category weight is 0%, the improvement activities performance category weight is 15%, and the promoting interoperability performance category weight is 30%. This change will occur automatically, so providers do not need to take any additional action. For the 2022 performance period, the cost category will no longer be reweighted in its entirety; however, the CMS stated that individual cost measures can be suppressed if the data used was “impacted by significant changes during the performance period.”