The Centers for Medicare & Medicaid Services (CMS) recently announced relief for clinicians participating in the Quality Payment Program (QPP) for 2020.
This relief only applies to clinicians attesting to the Merit-based Incentive Payment System (MIPS), not to Medicaid Promoting Interoperability (PI) or Alternative Payment Model (APM) entities. We will continue to monitor Medicaid PI and APM updates for any announcements regarding relief.
If you were impacted by the COVID-19 crisis and haven’t maximized performance in MIPS, you can submit an Extreme and Uncontrollable Circumstances Application to re-weight performance categories for the 2020 performance period. Due to COVID-19, you can have your MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0%. The deadline for submitting the application is Dec. 31, 2020. Review the 2020 Exception Applications Fact Sheet, as updated, for more information.
To determine whether you should submit this application, consider your performance during the 2020 reporting period and your circumstances. If you performed well, you can still choose to participate and submit data in a minimum of any two performance categories in order to receive a MIPS final score greater than the performance threshold, subject to new reweighting guidelines. If fewer than two performance categories can be scored, you will receive a final score equal to the performance threshold and will receive a neutral payment adjustment. Data submission overrides the performance category reweighting approved through your application on a category-by-category basis, except for the Cost performance category as it has no data submission requirements.
Here’s an example from the CMS QPP 2020 MIPS Exception Fact Sheet (June 24, 2020 version):
“You, a MIPS eligible clinician, submit an application to have all four performance categories reweighted, but later determine you are able to collect and submit data for the Improvement Activities and Promoting Interoperability performance categories. You will receive a MIPS final score based on the data submitted; the Improvement Activities performance category will be weighted to 15% and Promoting Interoperability performance category will be weighted to 85% of your final score. The Quality performance category will retain a 0% weight because you didn’t submit Quality data. The Cost performance category will retain a 0% weight because there are no data submission requirements associated with the Cost performance category.”
If you decide to submit the application, be sure to include a detailed explanation of how the pandemic has impacted your practice and the associated time frame. You are not required to submit documentation with your application. However, it is recommended that you retain documentation of your circumstances for your own records for data validation or in the event of an audit.
For more information, consult these resources:
- QPP COVID-19 Response page
- QPP Resource Library (2020 MIPS Exceptions Application Fact Sheet and more)
- QPP Exception Applications page
- Extreme and Uncontrollable Circumstances Application
- QPP Access User Guide (information on how to register for a HARP account)
- Contact QPP at QPP@cms.hhs.gov or 1-866-288-8292