Acknowledging that physician practices are focusing on providing quality care during the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) has finalized several important changes to the Quality Payment Program (QPP).

Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs)

After previously finalizing Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for implementation into the program during the 2021 performance period, CMS has decided to delay introducing MVPs into the program. Instead, CMS is implementing modifications to the MVP framework guiding principles and development criteria to support stakeholder collaboration with the agency to develop and recommend MVPs. AASM has been engaging with CMS and other medical specialty societies to identify opportunities to provide input on the MVP development process and MVPs that may be relevant to sleep medicine. CMS also finalized the MVPs guiding principles to include the patient voice, subgroup reporting, and promotion of digital performance measure data submission. Lastly, CMS also finalized a set of criteria to be considered when creating MVP candidates, starting with the 2022 performance period.

APM Performance Pathways (APPs)

CMS has made many other significant changes to the program including finalizing the APM Performance Pathway (APP), which aligns with the MVP framework. The new APP reporting framework begins in 2021. The APP is available only to participants in MIPS APMs and can be reported by the individual eligible clinician, group, or APM Entity.

The APP will have a quality measure set consisting of:

  • The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey measure
  • 2 measures that will be calculated by CMS using administrative claims data
  • 3 quality measures that can be reported as electronic clinical quality measures (eCQMs), MIPS CQMs, or Medicare Part B claims measures
    • For the 2021 performance period only, participants in accountable care organizations (ACOs) have the option to report the 10 CMS Web Interface measures in place of the 3 eCQMs/MIPS CQMs in the APP.

Performance Threshold

AASM had previously commented on the CMS proposals, regarding the performance threshold. CMS finalized maintaining the performance threshold at 60 points for the 2021 performance period, as previously finalized in the calendar year 2020 Quality Payment Program Final Rule.

Several additional changes were made to the quality, cost, improvement activities, and promoting interoperability categories of the Quality Payment Program. Review these additional changes in the 2021 Quality Payment Program Final Rule Resources available in the Quality Payment Program Resource Library.

Eligible Clinicians may contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8 a.m. – 8 p.m. Eastern Time or by email at