Physicians and other MIPS-eligible providers may not have to submit data for the 2020 MIPS program if the COVID-19 pandemic has prevented them from collecting 2020 data or is likely to impact their performance on cost measures.
The Centers for Medicare and Medicaid Services (CMS) recently announced that providers affected by the COVID-19 pandemic may apply for a MIPS Extreme and Uncontrollable Circumstances Exception. The hardship exception application allows providers to request one or more performance categories be reweighted to 0 percent.
According to CMS, both the circumstances and timing of the effects of COVID-19 will be considered when assessing the provider’s ability to submit data for each performance category selected in the hardship exception application. For example, the performance period for Improvement Activities is a continuous 90-day period whereas the performance period for the Quality performance category is 12 months. If the effects of COVID-19 lasted for three months, that may have more impact on the provider’s ability to successfully report Quality measures than to perform and attest to Improvement Activities.
If a hardship exception is granted for a performance category and the provider later submits data for that performance category, the submitted data will overwrite the hardship exception. This will not apply to the cost performance category, however, since no data is submitted by providers in that category.
Also, in order to receive a MIPS final score greater than the performance threshold, which would potentially allow providers to receive a positive payment adjustment, a provider must be scored on at least two performance categories. If only one performance category is scored for the 2020 MIPS performance period, the provider will receive a final score equal to the performance threshold resulting in a neutral payment adjustment in 2022.
Remember that certain provider types and providers with certain special statuses are eligible for automatic reweighting in the Promoting Interoperability Performance Category and don’t need to apply for a hardship exception in that category, including:
The following clinician types:
- Physician assistant
- Nurse practitioner
- Clinical nurse specialist
- Certified registered nurse anesthetist
- Physical therapist
- Occupational therapist
- Qualified speech-language pathologist
- Qualified audiologist
- Clinical psychologist
- Registered dietitian or nutrition professional
And providers with the following special statuses:
- Ambulatory Surgical Center (ASC)-based
- Non-patient facing
Providers have until 8 p.m. ET on December 31, 2020, to submit their Extreme and Uncontrollable Circumstances Exception application using the steps below:
- Register for a HARP account if you don’t already have one.
- Sign in to qpp.cms.gov
- Select ‘Exceptions Applications’ on the left-hand navigation
- Select ‘Add New Exception’
- Select ‘Extreme and Uncontrollable Circumstances Exception’
- Complete the application for individual, group or virtual group participation
- In the Additional Access section of the application, include the email address(es) of additional staff or representatives who should receive notifications about the status of the application.
According to CMS, providers “will need to provide a justification of how their practice has been significantly impacted by the public health emergency” but are not required to submit documentation with their hardship exception applications. However, they should document their hardship circumstances for their own records in case of a CMS audit.
For more information about submitting a hardship exception application, review the 2020 Quality Payment Program (QPP) Exception Applications Fact Sheet [automatic download from CMS]. You can also visit the QPP Exceptions webpage.
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