CMS Reweighting 2021 MIPS Cost Performance Category

May 6, 2022
Policy Snapshot

The Centers for Medicare & Medicaid Services (CMS) recognizes the impact that the COVID-19 pandemic public health emergency (PHE) continued to have on clinicians and the services they provided in the 2021 performance period.

Due to COVID-19’s impact on cost measures, CMS is reweighting the cost performance category from 20% to 0% for the 2021 performance period. The 20% cost performance category weight will be redistributed to other performance categories in accordance with § 414.1380(c)(2)(ii)(E). Please see the table that is part of the link for reweighting scenarios.

Why CMS is Reweighting the MIPS Cost Performance Category for 2021

Cost was already reweighted to 0% for all individual Merit-based Incentive Payment System (MIPS)-eligible clinicians, even if data were submitted for other performance categories, due to the automatic extreme and uncontrollable circumstances (EUC) policies under § 414.1380(c)(2)(i)(A)(6) and § 414.1380(c)(2)(i)(C). CMS’ 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.

Given these circumstances and in accordance with § 414.1380(c)(2), CMS will assign a weight of 0% to the cost performance category for the 2021 performance period and redistribute the prescribed weight of 20% to another performance category or categories.

Specifically, CMS doesn’t believe it can reliably calculate scores for some of the cost measures that would adequately capture and reflect the performance of MIPS-eligible clinicians based on the following reasons, as shown by analysis of the cost performance category data for the 2021 performance period:

  • 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.      

Please note that starting with the 2022 performance period, instead of reweighting the entire cost performance category, individual cost measures can be suppressed if the data used to calculate the score was impacted by significant changes during the performance period, such that calculating the cost measure would lead to misleading or inaccurate results. This provision allowing greater flexibility was finalized in the CY 2022 Physician Fee Schedule Final Rule.

Clinicians don’t need to take any action as a result of this decision because the cost performance category relies on administrative claims data.