Between presidential administration changes, a tough pandemic year and looming deadlines, it can be difficult to keep up with all the important updates to the Medicare Shared Savings Program (MSSP). To help you stay on track, we have outlined the most important things you need to know in the coming months, including:

Mandatory Quality Changes Coming in 2022
Quality reporting options that were optional in 2021 will become mandatory next year, including:

  • QPP APM Entity. 2021 will be the last year the CMS Web Interface is permitted for collection and submission for reporting MIPS quality measures. In 2022, the CMS Web Interface will no longer be an option, and data submission by Electronic Health Record (EHR) or Registry will be the standard.
  • Required Quality Measure Reporting. Starting in 2022, reporting on three measures will be required:
    • Diabetes: Hemoglobin A1C (HbA1c) Poor Control (>9%)
    • Controlling High Blood Pressure
    • Screening for Depression and Follow-Up Plan
  • NAACOS and Other Groups Urge CMS to Walk Back Quality Changes. The National Association of Accountable Care Organizations (NAACOS) has joined several medical groups in urging CMS to walk back the quality overhaul, giving healthcare organizations more time to adopt and implement new electronic measures. These groups have petitioned U.S. Secretary of Health and Human Services Xavier Becerra to take actions that would delay ACO quality reporting changes and make further modifications to ACO quality evaluations.

Promoting Interoperability Options for 2021
The HIE Bi-directional exchange measure is a new measure for reporting in performance year 2021. This measure serves as an alternative measure to two existing required HIE objectives. In 2021 you’re expected to report one of two options:

  • The two original HIE measures:
    1. Support Electronic Referral Loops by Sending Health Information
    2. Support Electronic Referral Loops by Receiving and Reconciling Health Information
  • Or the new Health Information Exchange (HIE) Bi-Directional Exchange measure—The MIPS eligible clinician or group must attest that they engage in bi-directional exchange with an HIE to support transitions of care. This measure requires that the MIPS-eligible clinician must attest yes or true to the following:
    • I participate in an HIE in order to enable secure, bi-directional exchange to occur for every patient encounter, transition or referral, and record stored or maintained in the EHR during the performance period in accordance with applicable law and policy.
    • The HIE that I participate in is capable of exchanging information across a broad network of unaffiliated exchange partners including those using disparate EHRs and does not engage in exclusionary behavior when determining exchange partners.
    • I use the functions of CEHRT to support bi-directional exchange with an HIE.

MSSP Pathways to Success Deadlines
Several key Pathway to Success deadlines are on the horizon, including:

  • Complete Notice of Intent to Apply (NOIA): June 1 – June 7, 2021
  • Submit Phase 1 Application: June 8 – June 28, 2021
  • RFI Responses: July 21 – September 10, 2021
  • Submit Phase 2—CMS Application Deadline: October 13 – October 19, 2021

You can learn more about the key features of Pathways to Success in a webinar VHAN hosted earlier this week. Watch the recording here. If you have any questions, please reach out to your network contact or email us at

CHART Model Delayed Until 2022
Through the Community Health Access and Rural Transformation (CHART) Model, CMS will aim to continue addressing disparities by providing a way for rural communities to transform their health care delivery systems by leveraging innovative financial arrangements as well as operational and regulatory flexibilities.

While this model could be ideal for providers seeking financial stability and reduced regulatory burden in rural areas across the southeast, the release date has been pushed back to spring 2022.

Stay tuned to VHAN communications for more details. We will continue to monitor MSSP changes and deadlines you need to know about. Look to future VHAN communications for more updates, or reach out to your network contact with any questions.