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MIPS Facility-Based Scoring Not Available for Performance Year 2021

For CFOs, finance & reimbursement staff, quality & patient safety staff

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In the federal fiscal year (FFY) 2022 inpatient prospective payment system (IPPS)/long-term care hospital (LTCH) PPS final rule, the Centers for Medicare & Medicaid (CMS) finalized a measure suppression policy for several hospital reporting programs. The policy is in response to the impact of the ongoing COVID-19 public health emergency (PHE).  

Under the policy, CMS suppressed seven measures for the FFY 2022 Hospital Value-Based Purchasing (VBP) Program, with all remaining measures in the clinical outcomes domain. CMS believes the resulting national comparison would not be fair and, therefore, finalized a special scoring policy for FFY 2022 that will not calculate a total performance score for any hospital in FFY 2022.   

CMS uses the total performance score from the hospital VBP Program to calculate Merit-based Incentive Payment System (MIPS) facility-based scores for facility-based clinicians and groups in the quality and cost performance categories. Because the FFY 2022 total performance score from the hospital VBP Program won’t be available, CMS will not be able to calculate MIPS facility-based scores for the 2021 MIPS performance year. 

Facility-based clinicians and groups will need to submit data on MIPS quality measures to CMS (except for administrative claims-based measures that have a benchmark, which are automatically calculated for clinicians and groups that meet the case minimum) to receive a score other than 0 for the quality performance category.  

CMS will automatically calculate a score for the cost performance category for facility-based clinicians and groups that meet the case minimum for at least one MIPS cost measure; there are no data collection or submission requirements for the cost performance category. If the facility-based clinician or group doesn’t meet the case minimum for any cost measures, the cost performance category will be reweighted to 0% and the weight redistributed to other performance categories.  

Facility-based clinicians and groups without available and applicable measures can submit an extreme and uncontrollable circumstances application citing “COVID-19” as the triggering event.  

Additional resources are available on the Quality Payment Program Resource Library: