## 2021 MIPS Step-by-Step Guides

Below are step-by-step guides on calculating, collecting and reporting each MIPS performance category; Quality (40 final MIPS points), Promoting Interoperability (PI, 25 final MIPS points), Clinical Practice Improvement Activities (CPIA, 15 final MIPS points) and Cost (20 final MIPS points). The Cost category does not require data submission and is scored through claims submitted to Medicare.

A maximum of 100 final MIPS score can be earned by achieving the full points in each category.

Practices will need to receive enough points to avoid a 9% penalty to their Medicare Part B Fee Schedule in 2023. For 2021, the minimum final MIPS score amount must be greater than or equal to 60 MIPS points to avoid the penalty. Any MIPS score achieved over 60 points could provide an incentive payment, anything below 60 points will result in a penalty.

For more information about the MIPS program and steps to take on getting started please review our MIPS page.

#### QUALITY Step-by-Step Guide (PDF file)

#### QUALITY Point Calculation

The Quality category accounts for 40 final MIPS points out of the possible 100 final MIPS score. This category requires a year’s worth of data (Jan. 1 to Dec. 31, 2021) on 6 selected measures. Each measure is worth up to 10 points (allowing for 60 category points total) and depending on performance physicians/practices will receive between 1 and 10 points per measure. Below is an example* of how this category would be scored:

*Dr. Smith reported on 6 quality measures. On three of her measures, she received the full 10 measure points, but on the other three she was only able to achieve 5 measure points each.*

(10 points x 3 measures) + (5 points x 3 measures) = 45 category points

45 category points ÷ 60 category points possible = .75 or 75%

*Because Dr. Smith achieved 75% of her category points, she can apply 75% of the 45 final MIPS Quality points available to her final MIPS score:*

40 final MIPS Quality points x .75 or 75% = 30 final MIPS points.

*Dr. Smith’s FINAL MIPS Quality score is 30 points, which will be counted towards her final MIPS score. This point total is less than the 60 MIPS points benchmark, therefore Dr. Smith will have to participate in other categories to potentially receive an incentive payment for achieving > 60 MIPS points.
*

*This example does not consider any possible bonus points practices could achieve such as the small practice bonus and others offered within MIPS.

#### PI Step-by-Step Guide (PDF file)

#### PI Point Calculation

The PI category accounts for 25 final MIPS points out of the possible 100 final MIPS score. This category requires a performance period of at least 90 consecutive days within 2021.

In 2019, unlike 2017 and 2018, there is a single set of Objectives and Measures to report. This single measure set includes new and existing Promoting Interoperability performance category measures organized under 4 objectives. Measures are no longer classified as base score or performance score measures.

For 2021, the PI category REQUIRES the use of 2015 Edition Certified EHR Technology (CEHRT) for participation. Participants must submit collected data for certain required measures from each of the 4 objectives measures (unless an exclusion is claimed) for 90 continuous days or more during 2021.

In addition to submitting measures, clinicians must:

- Submit a “yes” to the Prevention of Information Blocking Attestation;
- Submit a “yes” to the ONC Direct Review Attestation; and
- Submit a “yes” for the security risk analysis measure.

Note: A HIE Bi-Directional Exchange measure has been added and the bonus points for the optional Query of PDMP measure increased from 5 to 10 points.

Total available category points are 110 with a maximum capped category score of 100 points *(10 bonus points available to make total possible 110). *

The total PI performance category score will then be multiplied by the 25 final MIPS PI points available. This product is then added to the overall MIPS final score.

For example:

*Dr. Smith’s EHR is 2015 certified. After completing all the required PI measures Dr. Smith achieves 80 category points.*

80 category points ÷ 100 category points possible* = .8 or 80%

*We use 100 category points possible for this calculation rather than the total possible of 110 because this category is capped at 100 points.

*Because Dr. Smith achieved 80% of her category points, she can apply 80% of the 25 final MIPS ACI points available to her final MIPS score:*

25 final MIPS ACI points x .80 or 80% = 20 final MIPS points

*Dr. Smith’s FINAL MIPS ACI score is 20 points, which will be counted towards her final MIPS score. This point total does not meet the 60 MIPS points benchmark; therefore Dr. Smith need to submit data for another category along with the PI category to reach the 60-point benchmark and avoid a 9% penalty on her 2023 Medicare payments. *

#### CPIA Step-by-Step Guide (PDF file)

CPIA Point Calculation

The CPIA category accounts for 15 final MIPS points out of the possible 100 final MIPS score. This category requires each activity selected to be implemented within your practice for at least 90 consecutive days during 2021.

This category is attestation based, meaning when it is time to report only a “yes” or “no” statement is required for each activity completed. No documentation is required to be submitted but be sure to keep record of the activity completion in case of audit by CMS.

There are two levels of activities “medium” weighted or “high” weighted activities. Small practices (15 clinicians or fewer) can complete 1 high weighted activity (each worth 40 category points) or 2 medium weighted activities (each worth 20 category points) to achieve a full 40 out of 40 category points resulting in receiving the full 15 final MIPS points towards their final MIPS score. Below is an example:

*Dr. Smith works in a practice of 10 clinicians (considered a small practice). The practice has selected 2 medium weighted activities to complete for 2021 (activities completed by a practice can be attested to by an individual or group).*

(1 medium activity x 20 points) + (1 medium activity x 20 points) = 40 category points

40 category points ÷ 40 category points possible = 1 or 100%

*Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 15 final MIPS CPIA points available to her final MIPS score:*

15 final MIPS CPIA points available x 1 = 15 points

*Dr. Smith’s FINAL MIPS CPIA score is 15 points, which will be counted towards her final MIPS score. *

Larger practices (greater than 15 clinicians) will be required to do double the amount of activities to achieve a full 40 category points and get their 15 final MIPS points. Medium weighted activities for large practices are worth 10 category points each (requiring 4 be completed to achieve 40 points) and high weighted activities are worth 20 category points (requiring 2 be completed to achieve 40 points).

Note: a combination of high and medium weighted activities may be completed to achieve a full category score as long as a total of 40 category points are achieved.

#### Cost Point Calculation

Cost is not manually submitted and is measured behind the scenes at CMS using administrative claims data. Total number of category points available in the Cost category is determined by which measures apply to your practice, the maximum category points with all included measures is 100 points (10 eligible measures, up to 10 points each measure). Below is a points example for illustrative purposes only:

*Dr. Smith was informed by CMS that she was only eligible for 7 out of the 10 measures. She received 10 points on all 7 measures she was scored on.*

(7 measures x 10 measure points) = 70 points

70 category points ÷ 70 category points possible* = 1 or 100%

*Although there are 10 total measures, Dr. Smith was only eligible for 7 measures so she will only be scored on those that she is eligible for, bringing her total max category points to 70 rather than 100.

Because Dr. Smith (and her practice) achieved 100% of her category points, she can apply 100% of the 15 final MIPS CPIA points available to her final MIPS score:

20 final MIPS Cost points available x 1 = 20 points

#### Final MIPS Score for Dr. Smith:

*(Final MIPS Quality Score = 30) + (Final MIPS PI Score = 20) + (Final MIPS CPIA Score = 15) + (Final MIPS Cost Score = 20) = Total Final MIPS Score = 85*

*With a final MIPS score of 85 out of a possible 100, Dr. Smith will avoid a 9% penalty to her 2023 Medicare payments and will most likely receive incentive payments as well.*