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Recently CMS released the proposed rule for the 2021 Quality Payment Program (QPP), which covers both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).
For MIPS, there was speculation leading up to the release of the rule about how the COVID-19 pandemic would impact the program for 2020 and 2021. A thorough analysis of the proposed rule can be summarized at the highest level by saying that the COVID-related impacts are relatively minor, and ultimately, both 2020 and 2021 will require full participation for MIPS eligible clinicians and groups.
For APMs, and in particular Shared Savings ACOs, the proposed changes are much more significant, and have meaningful strategic and operational impacts on clinicians and entities participating in these payment models.