The Centers for Medicare & Medicaid Services (CMS) has announced some needed relief to Merit-based Incentive Payment System (MIPS) reporting requirements. MIPS is the major quality reporting program in Medicare for physicians.
CMS announced changes to the 2019 performance period in March, but refined its policies for the 2020 performance period in June.
2019 Performance Period
You were originally required to submit your 2019 performance data by March 31, 2020. CMS extended the deadline for reporting to April 30, 2020. If you did not submit MIPS data by April 30, 2020, you will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year (i.e. if you didn't report, you will be held harmless.) For more details on your reporting options, please see CMS' fact sheet.
If you did submit 2019 data, you can now review your preliminary score by logging onto the Quality Payment Program website. Please keep in mind that this is not your final score or feedback. Your final score and feedback will be available in July 2020.
2020 Performance Period
CMS announced on June 24 that you can submit an application to have your MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0% due to COVID-19.
Specifically, if the COVID-19 pandemic prevents you or your group from collecting 2020 MIPS performance period data for an extended period of time, or could impact your performance on cost measures, you can submit an extreme and uncontrollable circumstances application through December 31, 2020.
On July 13, ACEP had a call with CMS to find out more about the hardship exemption application process.
- CMS stated on the call that the agency is being extremely flexible of granting hardship exemptions due to COVID-19. In the application, there is an open text box that allows you or your group to explain why you are requesting a hardship exemption. CMS told ACEP that as long as you include as part of your rationale that you are claiming the hardship exemption because of your inability to report due to “COVID-19” or the “coronavirus,” CMS will most likely grant your exemption request. CMS did note that the operative words to use in your application are “COVID-19” and “coronavirus.” CMS will not be requiring you to submit documentation and is trying to make the application process as easy as possible.
- CMS stated that it will likely approve individual hardship exemptions within 24 to 48 hours after the request is submitted. As stated above, you can apply for the hardship exemption now until the end of the calendar year.
- CMS did say that if you claim a hardship exemption and then still submit data, it will score the data submitted and override the hardship exemption. For example, if you submit a hardship exemption for all four MIPS performance categories (and it is approved), but then decide to submit data on two performance categories later on, CMS will use the data submitted to determine a MIPS performance score.
For more information on submitting a hardship exemption for the 2020 performance period, and to apply, please go to CMS’ website here.
This MIPS relief was one of the major requests that ACEP included in our letter to the Secretary of the Department of Health and Human Services (HHS) on March 13th.