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The newly published 2021 CMS Physician Fee Schedule and Quality Payment Program (QPP) Proposed Rule reflects our harsh reality: Operate under the constraints of the COVID-19 pandemic, while moving toward uniformity and Risk. That tension is palpable in the Proposed Rule’s “push-pull” of CMS trying to continue to advance a Value agenda while stuck in the mud of the pandemic.
Rather than launching the next step of integrating CMS quality improvement activities, the Proposed Rule stays the current course for MIPS Quality Reporting to avoid additional stress on providers during the COVID-19 pandemic. But the Proposed Rule also continues to clear the path toward a common system of quality measurement for all providers, and toward financial Risk.
CMS explicitly declares that a public health emergency is not the time to make big program changes, delaying the MIPS Value Pathways (MVPs) model until 2022. However, the Proposed Rule— which also covers Physician Fee Schedule (PFS) modifications for 2021—includes provisions for new, permanent telehealth codes.