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.
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 be allowing clinicians eligible to participate in MIPS (most emergency physicians) to claim a hardship exemption due to COVID-19 for the 2021 performance period. CMS is allowing you or your group to submit an online application and request an exemption for one or more of the four MIPS performance categories if your practice was adversely affected by COVID-19. If you or your group request an exemption from all four performance categories, you or your group will not receive a MIPS payment adjustment in 2023 based on your performance in 2021. In other words, you or your group will not be required to report any data and you or your group will be held harmless from any possible downward payment adjustments (you or your group will also not be eligible for a bonus either).
To apply for a hardship exemption, please click here. Applications are due on December 31, 2021.
2020 Performance Period
CMS announced on February 25, 2021 that clinicians 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 didn’t report data, you will be held harmless and will not receive a bonus or penalty in 2022 based on your performance in MIPS in 2020. You still had the option of submitting data by March 31, 2021 and receiving a performance score. If you did choose to submit enough data to receive a score, your automatic exemption was overridden. On May 20, 2021, CMS announced that it would not score the Cost category for 2020 due to an insufficient amount of data. Therefore, if you did submit enough data to receive a MIPS performance score in 2020 (and your automatic exemption was overridden), your final MIPS score will NOT take into account your performance in the Cost category.
For more information on submitting a hardship exemption for the 2020 performance period, please go to CMS’ website here.