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February 25, 2021

Updated: CMS Announces MIPS Relief

Background
The Centers for Medicare & Medicaid Services (CMS) has announced some needed relief to Merit-based Incentive Payment System (MIPS) reporting requirements due to the COVID-19 pandemic. MIPS is the major quality reporting program in Medicare for physicians. 

2020 Performance Period

CMS announced on February 25, 2021 that clinicians eligible to participate in MIPS (most emergency physicians) will receive an automatic exemption from all four MIPS performance categories (MIPS Quality, Cost, Improvement Activities, and Promoting Interoperability performance categories) if they do not report any data from the 2020 performance period. In other words, if you haven’t yet reported data and choose not to do so, you will be held harmless and will not receive a bonus or penalty in 2022 based on your performance in MIPS in 2020. This represents a CHANGE IN POLICY. Previously, you were required to fill out an application to receive an exemption, and there was no automatic exemption.

You still have a few other options if you want to receive credit for participating in MIPS. You can choose to submit 2020 performance data and will receive a MIPS score (and be eligible for a bonus or penalty in 2022) if you: 1) submit data in 2 or more performance categories if you participate in MIPS as an individual; or 2) submit data for one or more performance category if you participate in MIPS as part of a group. If you do choose to submit enough data to receive a score, your automatic exemption will be overridden.

If you are reporting as part of a group, and you’ve submitted data on one performance category, CMS will still allow you to submit an application to request reweighting in all 4 performance categories.

The deadline for submitting a hardship exemption application has been extended from February 1, 2021 to March 31, 2021 (at 8 pm EST). Individuals and groups that have already submitted data for 2 or 3 performance categories can’t submit an application to override previously submitted data. You’ll receive a MIPS final score and MIPS payment adjustment ( a bonus or a penalty) in 2022 based on the data you’ve submitted.

For more information on submitting a hardship exemption for the 2020 performance period, please go to CMS’ website here.

2021 Performance Period

CMS announced in the Calendar Year 2021 Physician Fee Schedule (PFS) and Quality Payment Program (QPP) final rule that the agency would also be allowing clinicians to claim a hardship exemption due to COVID-19 for the 2021 performance period. More details on the exemption process will be forthcoming, but we expect clinicians to be required to fill out an application, as was initially required for 2020.

This MIPS relief was one of the major requests that ACEP included in our letter to President-Elect Joe Biden on November 24th.

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